The Measure Applications Partnership (MAP) provides pre-rulemaking guidance to the U.S. Department of Health and Human Services (HHS) for the inclusion of performance measures in public reporting and performance-based payment programs. This column discusses what surgeons need to know about the recommendations provided by the American College of Surgeons (ACS) on performance measures before they are included in federal regulations. This input is critical because the MAP identifies quality measures for more than 20 federal programs, many of which affect the delivery of and access to surgical care.*
What is the function of the MAP?
For the first time in national quality measure development, the Affordable Care Act (ACA) made way for significant enhancements to the traditional federal rulemaking process by providing a forum for public and private partnerships to provide feedback on quality measures before they are included in federal regulations. HHS selected the National Quality Forum (NQF) to provide this pre-rulemaking input guided by the three-part aim of the National Quality Strategy: better care, better health, and lower cost.* The NQF is an independent not-for-profit organization that has set the standard for the science of quality measurement validation and provides quality measures with NQF endorsement based on a rigorous multi-stakeholder consensus-based measure review.
To fulfill the ACA mandate, the NQF convened the MAP, which is charged with identifying core measures and prioritizing measure gaps in federal quality programs. The MAP provides guidance to foster alignment across quality programs, settings, levels of analysis, populations, and between public and private sector programs.† The MAP comprises four main workgroups: Clinician Workgroup, Hospital Workgroup, Post-Acute Care/Long-Term Care Workgroup, and Dual-Eligible Beneficiaries Workgroup—all of which are overseen by a MAP Coordinating Committee. Multi-stakeholder workgroups include members representing consumers, purchasers, labor, health plans, clinicians and other providers, communities and states, and suppliers.†
What is pre-rulemaking and the significance of providing guidance to HHS?
Each December, HHS provides a list of measures under consideration across 20 federal programs for the upcoming calendar year to the MAP for review. The MAP’s third cycle of pre-rulemaking recommendations were submitted earlier this year, and they provided feedback for 234 measures under consideration.‡ The MAP workgroups convene to review measures for programs relevant to their care setting or patient population and provide a final report to HHS in February. This process is guided by the MAP’s Measures Selection Criteria, which the MAP has developed to assist in identifying ideal measures for use in federal programs.‡ The pre-rulemaking process is an upstream approach to the implementation of measures to allow for increased transparency and multi-stakeholder input.
How does the MAP affect surgical care?
As part of the ACA, HHS is mandated to implement various programs that will measure surgical care, including metrics reported on Physician Compare and included in the Value-Based Payment Modifier pay-for-performance program. The ACS believes that surgeons, in consultation with their patients, working through their specialty societies and with quality measurement experts, are the most qualified to determine the appropriate metrics to measure surgical care for federal quality programs.§ Therefore, guidance from surgeons is critical in the MAP process to help identify measures that have the following attributes:
- Are clinically relevant for the assessment of provider function
- Meet the highest standards of validity and reliability to avoid misclassification
- Are equitable and feasible
- Are truly effective in assisting patient choice and access
- Are designed to stimulate surgical care improvement.§
How does the College contribute to the MAP?
As an organizational member of the MAP Coordinating Committee and through Fellow appointments, the ACS has played a leadership role in the MAP and is a recognized key contributor. Currently, Frank Opelka, MD, FACS, Associate Medical Director of the ACS Division of Advocacy and Health Policy, chairs the MAP Hospital Workgroup, and is the ACS organizational representative to the MAP Coordinating Committee. Erica Whitacre, MD, FACS, director of the Breast Center of Southern Arizona, is a breast surgeon in Tucson, and serves as a surgical subject matter expert on the MAP Clinician Workgroup. The ACS also is actively involved in the development of the MAP’s recommendations and provides comments to the Measure Applications Partnership Pre-Rulemaking Report Public Comment Draft each January.
*National Quality Forum. Measure Applications Partnership 2014 recommendations on measures for more than 20 federal programs: Final report. Available at: http://www.qualityforum.org/Setting_Priorities/Partnership/Measure_Applications_
Partnership.aspx. Accessed February 13, 2014.
†National Quality Forum Measure Applications Partnership. Available at: http://www.qualityforum.org/Setting_Priorities/
Partners hip/Measure_Applications_Partnership.aspx. Accessed February 13, 2014.
‡National Quality Forum. Measures Selection Criteria. Available at: http://www.qualityforum.org/Setting_Priorities/
Partnership/Measure_Applications_Partnership.aspx. Accessed February 13, 2014.
§Surgical Quality Alliance. Surgery & Public Reporting: Recommendations for Issuing Public Reports on Surgical Care. Available at: http://www/ahp/sqa/2014SQA_PublicReportingDocument.pdf. Accessed March 18, 2014.