Today MedPAC posted a comment letter to CMS on the list of Medicare quality measures under consideration for use in Medicare’s quality reporting or value-based purchasing programs. This year’s “list of measures under consideration” is a 329-page document listing hundreds of quality and resource use measures. Under the statute, CMS may consider including any of these measures during upcoming rule-making for its quality program. The list does not include the dozens of measures already adopted for Medicare’s quality programs, only potential new measures.
MedPAC’s comments reflect a growing concern among the Commission about Medicare’s current approach to quality measurement. In our June 2014 Report to Congress, MedPAC conveyed its assessment that Medicare’s current quality measurement approach is becoming “over-built,” and is relying on too many clinical process measures that are, at best, weakly correlated with health outcomes. Depending on a large number of process measures reinforces undesirable payment incentives in FFS Medicare to increase the volume of services and is overly burdensome on providers to report, while yielding limited information to support clinical improvement or beneficiary choice. Instead the Commission has urged more focused attention on a small number of population-level outcome measures, such as potentially avoidable hospital admissions, emergency department visits, and readmissions.
In our June 2014 report to the Congress, we acknowledged that these population-based outcome measures would not be appropriate for adjusting FFS Medicare payments within a local area, because FFS providers have not explicitly agreed to be responsible for a population of beneficiaries. Therefore, at least for the foreseeable future, FFS Medicare will need to continue to rely on some provider-based quality measures to make payment adjustments.
However, the sheer size of the December 2014 list of measures under consideration reinforces our concerns that Medicare’s provider-level measurement activities are accelerating without regard to the costs or benefits of an ever-increasing number of measures. We urge CMS to keep this broader perspective in mind as it moves into the proposed rule process for each Medicare program, and carefully consider whether each additional measure would simply reinforce or exacerbate the current system’s problems.