We are taking a page from manufacturers’ development play books as we seek input from the public on new draft clinical quality measures (CQMs).

Despite aggressive efforts to institute quality assurance in the eCQMs released as part of Stage 2, there were errors that made it through and were included in the final rule. ONC and CMS have — over the last year — moved from waterfall (batch) development and release to a more agile process using single-piece flow. Many US industries have found considerable improvement in their products and efficiency by applying a lean manufacturing approach, which we are trying to mirror in the development of new CQMs. Benefits of this approach include early error recognition, a more robust quality assurance process and a more streamlined review and correction phase that allows flexibility for our analysis and your feedback. This also allows the people interested in these products to review them as they have time throughout the year, rather than trying to provide feedback all at once. Another key goal is to get input much earlier in our measure development processes. Often feedback that arrives late is much harder to incorporate into the CQMs than input that arrives early. Towards that end, CMS and ONC have developed methods to obtain early and iterative feedback on draft MU3 measures currently under development, although the rule-making process has not concluded and there is no guarantee of inclusion of the changes in the final rule.

1. Reiterating a big policy change that was made in the 2014 Edition final rule; and
2. Providing some data and insights into comparisons between 2014 Edition and 2011 Edition certification numbers.

ONC and CMS welcome early review and comments on draft specifications, and have created multiple venues to accept this feedback:

Measure development organizations including NCQA, Yale COR, and Quality Insights of Pennsylvania, help develop measures. As a routine part of their process they post measure specifications for feedback.

A centralized way to provide feedback is through the AHRQ USHIK website. You can view specifications, including human readable HQMF and value sets with a UMLS license and provide comments to the USHIK site. CMS also has links for draft measures under development by their team on their website .

You can report comments or concerns regarding any of the above measures after getting a free login.

Finally, there is an opportunity to provide comment to CMS for measure concepts that may be proposed in stage 3. Some of these measures are still in the development process, so you can look for them on their developers website or at the AHRQ site as they are built. In the meantime, CMS would love your input.

While we realize that reviewing draft measures can be burdensome and time consuming, CMS and ONC are committed to higher quality, more implementable, and better aligned measures. We appreciate continued help from the public and the provider and vendor communities towards ongoing quality improvement.