The Centers for Medicare & Medicaid Services (CMS) Measures Management System (MMS), describes various roles that CMS has identified with respect to the measure development and maintenance process, including measure stewards (or owners), measure developers, and measured entities. The purpose of the clarifications below is to discuss CMS perspectives and expectations of various measure development roles.  

The Measures Management System (MMS)

The MMS includes resources and technical guidelines to assist measure developers, stewards, measured entities and support development and implementation of robust health care quality measures that are evidence-based, scientifically reliable, valid, and impactful. The MMS includes resources and tools such as the CMS Measures Inventory Tool (CMIT), CMS Measures Under Consideration Entry / Review Information Tool (MERIT), and the CMS Measures Management System (MMS) Hub. The MMS Hub houses technical content previously found in the CMS MMS Blueprint including information related to the Blueprint Measure Lifecycle, Measure Conceptualization, Measure Specification, and Measure Testing. CMS contractors must refer to and use the MMS since it is the key source for guidelines related to quality measure development and maintenance information.  

Although not required, CMS encourages measure developers who do not currently hold CMS contracts to use the CMS MMS as a guide to inform their measure development process, particularly if they are interested in submitting their quality and efficiency measures for future consideration in CMS programs.

Measure Stewards (or Measure Owners)

A measure steward is responsible for the oversight, quality and maintenance of a measure throughout its lifecycle. Measure stewards serve as the primary and ongoing point of contact for answering questions and resolving issues related to the measure. A measure steward may focus on defining the measure, setting targets and benchmarks, data collection and analysis, and improvement actions.  The measure steward is ultimately responsible for the overall strategic direction and holds the authority to make final decisions related to design, specifications, testing, improvement and maintenance of a measure. The measure steward grants permission for measure use and application by others, approves any updates, and communicates such information to interested parties. Measure stewards may also be measure developers. The measure steward manages the day-to-day activities, facilitates stakeholder input, and is responsible for maintaining the measure. This role ensures that measures are used correctly, updated as necessary, and remain aligned with current practices, regulations, guidelines, and other clinical practices.  A measure steward may hold legal or intellectual property rights to a measure. In some instances, a measure may be developed and maintained without any associated intellectual property rights, particularly when it is intended for public use or falls under open-access frameworks.  

CMS does not generally have contracts with measure stewards and although not required, CMS encourages measure stewards, particularly those who intend to have measures considered in CMS programs, to fully participate in the following activities and functions related to measure processes including submission, review and maintenance of quality measures:

• Submit measure information to the CMS Measures Under Consideration Entry/Review Information Tool (MERIT) system, including measure title, description, and detailed information about any proprietary components and/or licensing fees required;
• Participate in Consensus-Based Entity (CBE) related measure review meetings and processes such as Endorsement & Maintenance, Pre-rulemaking Measure Review, and Measure Set Review. These processes support consensus recommendations for measure endorsement, for inclusion in the list of measures to be considered for CMS programs, and for continued use or removal from CMS programs, respectively;
• Provide measure details such as endorsement status, measure justifications for proposed use in CMS programs, and any other supplemental materials to support CMS during  federal rulemaking cycles, as needed;
• Collaborate with CMS to provide additional technical assistance resources such as measure guides for use, coding documents, to support stakeholder education if the measure is adopted for use in a CMS program;  
• Communicate to CMS, any plans to change a measure;
• Provide a one-year notice to CMS if the measure steward plans to discontinue supporting a measure used in a CMS program to give CMS enough time to propose measure removal through the required rulemaking process.  

Measure Developers

A measure developer is responsible for developing new measures or updating existing measures if any changes are required by the measure steward. Measure developers may also be measure stewards. If they are distinct entities, measure developers often collaborate with measure stewards to support the design, specifications, testing, improvement and maintenance of a measure to ensure measures are scientifically sound, feasible and meet standards for clinical care. Measure developers also monitor the performance of measures post-implementation, recommend adjustments to measure specifications, as necessary, to improve accuracy and effectiveness, and incorporate changes to align with clinical standards.  

CMS sometimes enters into contracts with measure developers who are required to participate in activities related to measure processes including submission, review and maintenance of quality measures that are considered and adopted in CMS programs. Although not required for measure developers that are not under contract with CMS, CMS encourages measure developers to fully participate in activities and functions related to measure submission and review outline in the above section describing measure steward roles and responsibilities.  If distinct entities, measure developers work in close collaboration with measure stewards to make determinations to submit measures to CMS for consideration and to provide measure details and information to support technical assistance and education for stakeholders.

Measured Entities

Measured entities are individuals, such as clinicians or health plans along with their organizations, systems, or programs, that are being measured. They collect and report the quality measurement data needed to meet program requirements and assess their performance. Measured entities are often involved throughout the Measure Lifecycle and work closely with measure stewards and measure developers to provide critical input on all aspects of a measure including its intended use, feasibility of data collection, and impact on individuals and delivery of care.

CMS

CMS is the measure steward for most measures developed by a measure developer under a CMS contract. At times, CMS is also a measure developer.  If CMS owns a measure developed under a CMS contract, it will not pay for the measure to be developed again. CMS provides use cases for measures not developed under a CMS contract and, therefore, will not cover licensing fees for measures developed by an external measure steward. If a measure steward requests that CMS take ownership of a measure, CMS will consider transfer of ownership (e.g., purchase of proprietary rights) on a case-by-case basis. CMS consideration to become a measure steward includes assessing the development stage of the measure, which will affect the cost required to complete measure development.