Comments to Mathematica and CMS on Quality Measures

October 7, 2016

TO: Mathematica Policy Research S

ent Via Email to

ACAP thanks you for the opportunity to submit comments to Mathematica on behalf of the Centers for Medicare & Medicaid Services (CMS)’s Center for Medicaid and CHIP Services (CMCS) and the MedicareMedicaid Coordination Office (MMCO), on measure specifications and justification for quality measures currently under development and testing. The measure concepts address the following areas and/or populations:

  • Medicare-Medicaid (dual eligible) beneficiaries and Medicaid beneficiaries using home and community-based services
  • Medicaid beneficiaries in managed long-term services and supports programs
  • Medicaid beneficiaries with complex care needs and high costs
  • Medicaid beneficiaries with substance use disorders
  • Medicaid beneficiaries and Medicare-Medicaid (dual eligible) beneficiaries with physical-mental health integration needs

ACAP is an association of 57 health plans in 24 states that serve 17 million Americans in Medicaid, Medicare, the Children’s Health Insurance Program, and low-income persons receiving coverage through the health insurance Marketplaces.

General Comment
We feel it necessary to note that the information provided was done so in a very confusing and inconsistent manner that was difficult to read. For future measures, we suggest modifying the format for presenting the measures for comment. In addition, the purpose and use of the measures is not clear in the documentation. Providing more context of the thinking behind the measures would be helpful in evaluating their usefulness. Finally, as a general comment on measure development, we do not support the addition of new hybrid measures, especially given that many providers, particularly behavioral health providers and small or solo physician practices lack EHRs.

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