In December 2014, CMS released a 329-page list of quality measures under consideration for the Medicare program. In a January 13, 2015 comment letter, MedPAC observes that volume 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.” MedPAC suggests that CMS is “relying on too many clinical process measures that are, at best, weakly correlated with health outcomes.” Moreover, including numerous process measures could reinforce “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.” While acknowledging that CMS includes more measures than will be adopted in order to solicit comments, MedPAC urges CMS to “carefully consider whether each additional measure would simply reinforce or exacerbate the current system’s problems.”

The following is MedPAC’s count of measures under consideration (note that the largest number of measures under review this year apply to accountable care organizations):

CMS program*

Number of measures under consideration

Medicare Shared Savings (ACOs)

116

Physician Feedback/Quality and Resource Utilization Reports

102

Physician Value‐Based Payment Modifier

102

Medicare Physician Quality Reporting System

96

Physician Compare

96

Medicare/Medicaid EHR Incentive Programs for Eligible Professionals

31

Hospital Inpatient Quality Reporting

29

Hospital Outpatient Quality Reporting

16

Hospital Value‐Based Purchasing

12

Ambulatory Surgical Center Quality Reporting

9

PPS‐Exempt Cancer Hospital Quality Reporting

9

End‐Stage Renal Disease Quality Incentive Program

7

Inpatient Rehabilitation Facility Quality Reporting

6

Inpatient Psychiatric Facility Quality Reporting

4

Long‐Term Care Hospital Quality Reporting

4

Medicare/Medicaid EHR Incentive Programs for Eligible Hospitals/CAHs

4

Hospital‐Acquired Condition Reduction Program

2

Home Health Quality Reporting

1

Hospital Readmission Reduction Program

1

Skilled Nursing Facility Value‐Based Purchasing Program

1

Hospice Quality Reporting

0

 *A single measure may be under consideration for more than one program.
Notes: ACOs (accountable care organizations); PPS (prospective payment system); CAHs (critical access hospitals).