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Public Comment Opportunity: Development and Testing of the Diabetic Foot Assessment and Follow-Up Clinical Quality Measure and Electronic Clinical Quality Measure

Monday, March 6, 2023

The Centers for Medicare & Medicaid Services (CMS) contracted with Mathematica to develop and test the Diabetic Foot Assessment and Follow-Up clinical quality measure (CQM) and electronic clinical quality measure (eCQM). The contract name is Electronic Clinical Quality Measures Development and Maintenance for Eligible Clinicians (EC eCQM). The contract number is 75FCMC18D0032/75FCMC19F0004.  As part of its measure development process, Mathematica requests interested parties to submit comments on the candidate or concept measures that may be suitable for this project. One goal of this project is to develop and test new clinician-level quality measures for use by providers in CMS quality-reporting programs.


The Call for Public Comment period opens March 6, 2023 and closes April 5, 2023.

Documents and Measures for Comment: 

You may access each document in the list by clicking its title:

Project-Specific Instructions: 

We are seeking feedback on all components of the proposed measure, as well as answers to the following questions:

  • To what extent do you feel the Diabetic Foot Assessment and Follow-Up measure will contribute to greater quality of care, reduced ulcers, and reduced lower-extremity amputations (LEA) for patients with diabetes? What changes, if any, should be made to the measure specification to meet the measure’s intent of reducing LEA?
  • How burdensome would this measure be for primary care providers to implement?
  • Are the current denominator exclusions appropriate (patients in hospice, palliative care, or long-term care; those with frailty or advanced illness; and those with bilateral lower-extremity amputation)? What other denominator exclusions would be appropriate, if any?
  • Are the quality actions—lower-extremity neurological assessment, vascular assessment, visual inspection for ulcer, patient education, and documentation of follow-up plans—appropriate for primary care providers? Are the quality actions defined appropriately?
  • Should the neurological assessment component require the Semmes-Weinstein monofilament AND at least one additional assessment (pinprick, vibration, ankle reflexes, or vibration perception threshold), or should it require only the monofilament?
  • Should the measure require documentation of ulcer risk level (for example, high risk, medium risk, or low risk) in addition to documentation of completed lower-extremity assessments? What are the benefits and burdens of documenting ulcer risk level?
  • Is the definition of “follow-up care” in the measure specification appropriate? If not, how should the definition be refined?
  • Should this measure be stratified by patient characteristics, such as race and ethnicity, to identify opportunities to address disparities in care?

To submit comments, please email the EC eCQM team at

  • Please do NOT submit anything that would constitute protected health information or personally identifiable information (such as dates of birth, Social Security numbers, or health insurance claim numbers) in your comments.
  • If you are providing comments on behalf of an organization, include the organization’s name and contact information.
  • If you are commenting as an individual, include your name and contact information.
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