Life Science Compliance Update

April 18, 2016

Quality Measure Core Set Implementation Plan

For the past three years, the Centers for Medicare and Medicaid Services (CMS) has worked to align quality measures across different public programs in an attempt to support consistent high quality care for patients and to reduce complexity and burden for clinicians in how they report on quality improvements. CMS has already aligned quality measures across acute care hospital programs, such as the Inpatient Quality Reporting Program, Hospital Value Based Purchasing, and the Hospital-Acquired Condition Reduction program. Hospitals report their quality measures once, which are then used for multiple programs.

CMS recently announced the release of seven sets of core clinical quality measures intended for use in multi-payer settings. These measures were selected to support multi-payer alignment on core measures primarily for physician quality measurement program, as measure requirements are often not aligned among payers, which often results in confusion and complexity for reporting providers.

The guiding principles used to develop the core measure sets are that they be meaningful to patients, consumers, and physicians, while reducing variability in measure selection, collection burden, and cost. The goal is to establish broadly agreed upon core measure sets that can be harmonized across commercial and government payers.

The seven core measure sets focus on the following areas: Accountable Care Organizations (ACOs), Patient Centered Medical Homes (PCMH), and Primary Care; Cardiology; Gastroenterology; HIV and Hepatitis C; Medical Oncology; Obstetrics and Gynecology; and Orthopedics.

The seven measures were selected as a part of a collaboration between CMS, America's Health Insurance Plans (AHIP), private payers, and other stakeholders, known as Core Quality Measures Collaborative, to establish "broadly agreed upon core measure sets that could be harmonized across both commercial and government payers." Current measures acted as a model for the new measure sets, and CMS plans to use the rulemaking process to introduce additional measures from the new sets into public reporting programs.

According to CMS Acting Administrator Andy Slavitt, "In the U.S. Health care system, where we are moving to measure and pay for quality, patients and care providers deserve a uniform approach to measure quality. This agreement … will reduce unnecessary burden for physicians and accelerate the country's movement to better quality."


Implementation will occur in several stages. When it comes to private payers, the measure sets will be phased in over time as contracts between providers and payers are renewed and renegotiated. The implementation of certain measures will depend on the provider's ability to collect and report data through their Electronic Health Record (EHR). While some plans and providers may be able to collect certain clinical data, a robust infrastructure to collect data on all the measures in the core set does not currently exist, and further infrastructure may be required for certain measures.

The Health Care Payment Learning and Action Network (HCPLAN), a public-private collaboration established by CMS, will integrate these quality measure into their efforts to align payment model components with public and private sector partners. In addition, CMS is working with federal partners (i.e., the Office of Personnel Management, Department of Defense, and Department of Veterans Affairs) and state Medicaid programs to further align quality measures.

Given ongoing local and regional efforts at quality improvement, provider performance on some of the measures in the core sets may be topped out in particular areas of the country or within a particular provider's patient population. Private payer-provider collaboration will help to determine the appropriate subset of core measures that should be implemented.

The Core Quality Measures Collaborative will use the upcoming year as a transitional period, as it begins to adopt and harmonize the measures. The Collaborative will continually monitor the use of these measures to modify them as needed, based on lessons learned. In addition to monitoring progress, the Collaborative will invite broader participation and add additional measures and measure sets.

Debra L. Ness, president of the National Partnership for Women & Families, believes that "alignment across payers is key to making sure measurement doesn't waste resources or create unnecessary burden. Ultimately, it plays a foundational role in achieving better health and better health care at lower costs."

December 05, 2014

National Quality Forum Begins Annual Review of Quality Measures, Comments Open December 23 on the 202 Proposed Measures


On Monday, the Measure Applications Partnership (MAP) began its annual review of performance measures that the Centers for Medicare and Medicaid Services (CMS) is considering for use in 20 federal health programs. The 202 measures considered by the group have been made public (view the  PDF), and will be available for review and comment beginning December 23, 2014.

Established by the National Quality Forum (NQF) in 2011, MAP is a forum of approximately 150 healthcare leaders and experts, representing nearly 90 private-sector organizations. MAP comprises consumers, purchasers, labor, health plans, clinicians and providers, communities and states, suppliers, and liaisons from seven federal agencies.

“MAP brings the public and private sectors to consensus on how quality can be measured effectively and efficiently in federal health programs,” said NQF President and CEO Dr. Christine Cassel. “A key goal for MAP is to streamline the measures used by the federal government so that patients receive the quality care they deserve and providers can focus on how best to improve the care they deliver.”

What do some of these 202 new measures look like?

The measures included for review cut across a wide variety of treatments. Measures included on the list cover preventative care and a number of conditions, including diabetes, asthma, surgery, and cancer.

One measure, x4208, looks at opioid addiction. It seeks to quantify the percentage of patients with a diagnosis of current opioid addition who were counseled regarding psychosocial and pharmacologic treatment options for opioid addition within the 12 month reporting period.

Another, measure x3798, quantifies how often patients with diagnosis of a muscular dystrophy had a scoliosis evaluation ordered. Measure E0056 measures how many patients with diabetes received a foot exam during the measurement year. Another measure seeks to curb "unnecessary colonoscopies" in patients over age 86, when the risks apparently are reduced (X3769).

Some measures are extremely detailed. For example, x3773, entitled "Optimal Asthma Care," covers a wide range of required testing, tracking, and patient education protocols.

The list of applicable Federal programs (available on pg. 6-7 of the PDF) includes:

  • Ambulatory Surgical Center Quality Reporting Program;
  • End‐Stage Renal Disease (ESRD) Quality Incentive Program;
  • Home Health Quality Reporting Program;
  • Hospice Quality Reporting Program;
  • Hospital‐Acquired Condition Reduction Program;
  • Hospital Inpatient Quality Reporting Program;
  • Hospital Outpatient Quality Reporting Program;
  • Hospital Readmission Reduction Program;
  • Hospital Value‐Based Purchasing Program;
  • Inpatient Psychiatric Facility Quality Reporting Program;
  • Inpatient Rehabilitation Facility Quality Reporting Program;
  • Long‐Term Care Hospital Quality Reporting Program;
  • Medicare and Medicaid Electronic Health Record (EHR) Incentive Program for Eligible Professionals;
  • Medicare and Medicaid EHR Incentive Programs for Eligible Hospitals or Critical Access Hospitals;
  • Medicare Shared Savings;
  • Medicare Physician Quality Reporting System;
  • Physician Compare;
  • Physician Feedback/Quality and Resource Utilization Reports;
  • Physician Value‐Based Payment Modifier Program;
  • Prospective Payment System‐Exempt Cancer Hospital Quality Reporting Program; and
  • Skilled Nursing Facility Value‐Based Purchasing Program.

Starting on p. 330, the pdf breaks down the CMS program that corresponds to each measure title.  

Download CMS List of Quality Measures


CMS notes that they are issuing this list of measures to comply with Section 1890A(a)(2) of the Social Security Act, which requires the Department of Health and Human Services to make publicly available a list of certain categories of quality and efficiency measures that it is considering for adoption through rulemaking for the Medicare program. “Because this List contains measures that were suggested to us by the public, this List contains more measures than will ultimately be adopted by CMS for optional or mandatory reporting programs under Medicare,” states the report. “When organizations, such as physician specialty societies, request that CMS consider measures, CMS makes every effort to include those measures and make them available to the public so that [MAP], the multi‐stakeholder groups convened as required under 1890A of the Act, can provide their input on all potential measures.” 

The measures considered by the group are made public at the beginning of the forum and will be available for review and comment beginning December 23, 2014.

November 11, 2014

“Continuing Medical Education” meets “Quality Improvement Education”


The Alliance for Continuing Education in the Health Professions is supporting an initiative to promote quality improvement programs through continuing education activities.

ACEhp members are invited to submit comments on the “Quality Improvement Education” Roadmap for the committees’ consideration until November 24, 2014. ACEhp will host a webinar this Friday, November 14, to discuss the Roadmap, provide feedback, and hear comments from colleagues.

We have featured an article written by Destry Sulkes, MD, MBA, Board President of the Alliance for Continuing Education in the Health Professions (ACEhp)


“Continuing Medical Education” meets “Quality Improvement Education”

Destry Sulkes, MD, MBA, Board President of the Alliance for Continuing Education in the Health Professions (ACEhp)

It’s no secret that a lack of coordination and continuity is a serious flaw in the nation’s health system. Even with electronic health records, an estimated 80 percent of serious medical errors involve some form of miscommunication.

As a healthcare education leader for over 15 years and current Board President of the ACEhp, it’s increasingly clear that continuing medical education (CME) must expand to all healthcare stakeholders, and focus more on the daily interactions among practitioners and their patients.

Until recently, CME and broader healthcare professional development has been very successful in helping us maintain competence, licensure requirements and to learn about new and developing areas of their field. Each profession and each medical specialty has outlined critically important updates in skills. But we’re realizing we have had our heads down too far. We’re missing the big picture.

“The Pennsylvania Project” is a perfect example of dramatic improvement in care made possible through an expanded focus on not just medical education, but a broader “inter-professional” education effort that focuses on National Quality Forum measures, in this case targeted to those at the center of the big picture – community pharmacists.

One in five prescriptions written are never filled, failing to improve patients’ health and reduce hospitalization. To address this problem, the project used the expertise and accessibility of pharmacists and care teams to keep patients on track in taking medications prescribed by their doctors.

The University of Pittsburgh School of Pharmacy trained care teams to screen patients to identify those at risk for missing or skipping medications for chronic conditions like diabetes, high-cholesterol, hypertension and heart disease.

This innovative “screening and brief intervention” approach, featured in the August 2014 Health Affairs, brought pharmacists and patients together to work through barriers like cost, side effects or silent symptoms that keep patients from taking medications as prescribed.

As part of “The Pennsylvania Project,” pharmacists access a cloud-based report card that keeps track of patient adherence by condition and compares rates to neighboring pharmacy patients. The monthly report cards spark conversations with patients who need more help with their medications. The patients are provided with more information about their medication and also have more interactions with their primary care physicians.

After a year, adherence rates significantly improved for all conditions tracked. An additional 1,500 patients in the project’s pharmacies started taking medications as prescribed to improve their health. This represents a 5% increase in adherence rates overall.

Non-adherence raises the risk for mortality from 12 to 25 percent for cholesterol-lowering statins and 50 to 80 percent for drugs that treat cardiac disease.  Medication non-adherence costs between $100 billion and $289 billion and 125,000 lives annually. A 1 percent improvement among Medicare patients is estimated to save the federal government $1.5 billion, according to the Congressional Budget Office.

We can no longer afford continuing medical education that operates independently of other healthcare professionals, patients, and quality improvement efforts. Bringing “quality improvement” and “continuing medical education” together is our “Eureka” moment in health care.

Pharmacists are an untapped source of patient engagement and quality improvement in health care. They train to get a doctorate in pharmacy and are uniquely positioned to see all the medications each patient is taking and all the practitioners who are prescribing them. It only makes sense for continuing education efforts to enlist pharmacists in quality improvement.

With the US healthcare environment in the midst of a refocus on results and outcome metrics versus quantity of services delivered, we have a great opportunity to bridge divides and forge a collective responsibility for better results. This new era of continuing education for health professionals creates new collaborations among healthcare stakeholders who haven’t traditionally worked together.

To jumpstart a more systemic focus on education’s role in quality improvement, ACEhp issued a Call for Comments on a Draft Quality Improvement Education (QIE) Roadmap. The QIE Roadmap will provide a vision for improving the quality of health care through continuous education of practicing health professionals. We see this as a prime opportunity for health education professionals and the practitioners they train to focus broad healthcare continuing education where it matters most – the daily interactions among and between health care providers and patients.

With so many new advances and discoveries being made in health care every day, continuing education for health professionals is one of the most challenging and critically important jobs. Now is a prime time to move from compliance-driven continuing medical education to performance-driven quality improvement education.  


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