Table 51- 2010 PQRI Measures Not Proposed for Inclusion in PQRI 2011
• The AMA supports the proposal to retire measures #114 and #115 and replace these retired measures with the new measure PCPI measure-Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention.
• Measure # 135: Chronic Kidney Disease-Influenza Immunization. The AMA respectfully requests that CMS reconsider measure #135 for inclusion in PQRI 2011. The proposed rule states that this measure was considered for National Quality Forum (NQF) Endorsement, but ultimately not NQF-endorsed. This is incorrect. Measure #135 has not yet been reviewed by NQF, and therefore still meets the requirements for inclusion in the CMS PQRI program.
Tables 52 & 53- Proposed 2011 Measures Selected from the 2010 PQRI Program
• The AMA supports the continued inclusion of the measures listed in Table 52. However, CMS should be aware that the PCPI has received inquires from various stakeholders related to Measure #193 – Perioperative Temperature Management. Based on inquiries received, which questioned how the process component of the measure is defined, the PCPI work group that developed the measure reconvened in 2010 to review the evidence base. Upon reviewing updated guidelines and other changes to the evidence base, the work group convened a webinar inviting open presentations from interested stakeholders in measure #193. The work group considered the relevance of evidence and information presented during the webinar to the existing definitions in the process component of the measure (i.e., definition of active warming). Additionally, the work group directed PCPI staff to draft for its consideration a potentially more clinically-relevant version of the measure focused on the outcome component only (i.e., maintaining normal intraoperative temperature). The revision of the measure is ongoing, and will require the development of detailed specifications, an open public comment period, and PCPI approval upon work group review of comments and final consensus on the measure.
Table 54: Proposed New Individual Measures for PQRI 2011
• Care Transitions Measures: The AMA appreciates that CMS recognizes the importance of the four Care Transitions measures and for this reason has included them in the measures proposed for PQRI 2011. While the AMA looks forward to implementation of these measures in a national program, the Care Transitions measures were not designed for individual physician level measurement. These measures are specified at the facility (hospital) level, using the UB04 administrative data to identify the denominator population. Given that one of the PQRI program requirements is that the measures are for services covered by the Physician Fee Schedule, it does not seem feasible to include these in the PQRI program. The AMA will work with the Society for Hospital Medicine to determine whether these measures would be appropriate for a hospital-level quality reporting program. As a point of clarification, the National Committee for Quality Assurance is incorrectly included as a joint measure developer on these measures. The measures were developed by the PCPI in collaboration with the American Board of Internal Medicine Foundation, the American College of Physicians, and the Society for Hospital Medicine.
• Hypertension: Plan of Care- The AMA-PCPI, in collaboration with the American College of Cardiology Foundation/American Heart Association (ACCF/AHA) recommends that this measure not be finalized for inclusion in PQRI 2011 individual measures (claims or registry) Hypertension-Plan of Care. When this measure was originally developed, it was developed as a “test measure” and was not designed for individual physician accountability, but rather internal quality improvement. The CAD/Hypertension measurement set is currently undergoing full maintenance and update by the PCPI/ACCF/AHA Measure Development work group. The expert work group has recommended that this measure be retired and will be replaced with another measure. The updated Hypertension measurement set is in its final stages of development, and the PCPI anticipates to have a new measure for consideration in PQRI 2012.
• Melanoma: Overutilization of Imaging Studies in Stage 0-IA Melanoma: this measure is proposed for either claims or registry reporting. The AMA would like to propose that the existing Melanoma measures #137 and #138 (currently registry only) also be proposed for either claims-based or registry-based reporting. This will provide consistency in reporting for dermatologists reporting on the Melanoma measures. In PQRI 2010, measures #137 and #138 are only available for registry-based reporting.
• Radiology: Reminder System for Mammograms; the AMA supports the inclusion of this new measure.
• Asthma: Assessment of Asthma Risk- Emergency Department (ED)/Inpatient Setting and Asthma: Discharge Plan- Emergency Department/Inpatient Setting. The AMA does not recommend these two measures be finalized for PQRI 2011 because they both are for the ED/Inpatient setting only and are not aligned in terms of care setting with the existing Asthma measures (#53, #64) in PQRI. CMS proposed an Asthma Measures Group for 2011 comprised of these two measures and the two existing Asthma measures in PQRI (#53, #64). However, as noted in comments for Table 70, these measures are not appropriate for inclusion in the Asthma Measures Group due to the varying settings of care. The AMA recommends that CMS consider adding the following Asthma measures for inclusion in PQRI 2011 for individual reporting (claims and registry) 1) Asthma: Tobacco Use: Screening- Ambulatory Care Setting; 2) Asthma: Tobacco Use: Intervention- Ambulatory Care Setting. The inclusion of these AMA proposed measures would enable CMS to proceed with creating an Asthma Measures Group unique to one setting of care.
• Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention; the AMA supports the inclusion of this updated PCPI measure for tobacco use.