External and Internal Inputs
While CMS may talk about external and internal inputs, the two types of inputs go hand in hand, and it may depend where you are in the Measure Lifecycle. The U.S. Congress provides legislation affecting CMS quality programs (legislative mandates), which usually leads to regulations using the rulemaking process. For example, section 3014 of the Patient Protection and Affordable Care Act requires a pre-rulemaking process in which the CMS Consensus-Based Entity must convene interested parties to provide input on the Measures Under Consideration (MUC) List. Next, the public provides comments on the MUC List. CMS may propose measures from the MUC List for use in a CMS program through the rulemaking process. The public may submit comments to CMS regarding these measures in proposed rules. Once CMS has considered all public comments, CMS may finalize the measures in a final rule.
The public (external input) can also comment on draft measure specifications, proposed rules (internal and external inputs), and can participate in technical expert panels (TEPs), focus groups, and similar activities. A subset of the public are patients and families, whose voice is critical to quality measurement topics. Subject matter experts (SMEs), either as individuals or representatives from organizations, can provide comments on proposed rules, the MUC List, and draft measure specifications. SMEs can also participate in TEPs, focus groups, and similar activities, and develop peer-reviewed publications. All can participate in activities such as providing comments on the National Quality Strategy or various quality program public presentations. Through these activities, individuals, families, and caregivers; measured entities; payors; specialty societies; advocacy groups; states; health plans; and other interested parties and experts with an interest in quality can help shape CMS policy and prioritization and planning of measures.
Congress required the National Impact Assessment Reports via an amendment to section 1890A(a) of the Social Security Act. Legislation mandates these and other internal reports. While the public may comment on these reports, CMS does not usually publish a request for comments. Whereas the Meaningful Measures Initiative and Cascade of Meaningful Measures are internal inputs developed by CMS to help with measure prioritization and planning.
- Resources
-
A selection of internal and external sources of inputs.
Cascade of Meaningful Measures
Congressional Legislative Activities
CMS Quality Measure Development Plan and Annual Reports
Meaningful Measures Initiative
National Impact Assessment of the CMS Quality Measures Reports