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Next Steps for Protecting QCDR Measure Integrity

Wednesday, December 5, 2018   (0 Comments)
Posted by: Bevin Rousopoulos
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Next Steps for Protecting QCDR Measure Integrity


Health care quality improvement stakeholders notched a victory when CMS delayed the provision to:

Allow the use (without modification) of any submitted and approved measures at no cost to other QCDRs. Should a QCDR refuse to go into agreement with CMS, the measure(s) in question will be rejected and another similar measure may be approved in its place.” (42 CFR § 414.1400 (b)(3)(ii)(C))

This would have forced operators of Qualified Clinical Data Registries (QCDR) to license their measures for use by others at no cost. The proposed requirement was excluded from the final 2019 physician payment rule in response to comments from PCPI and other affected organizations.  Many commented that it threatened the integrity of measures as well as the financial viability of new measure development – and could even discourage specialty society participation in the QCDR program.

In the wake of measure proliferation, CMS has emphasized the need to find ways to stem the tide of duplicative measures.  CMS is open to modifying how to promote measure harmonization and has asked for feedback from users on how the process might be improved before any future implementation. At the PCPI Fall Conference 2018, participants brainstormed a range of ideas for addressing CMS’ goals while protecting the integrity and viability of QCDR measure development and use such as:


  • Promoting Harmonization and Reducing Duplication

  • Unintended Consequences from Forced Measure Sharing


We invite you to strengthen our message to CMS regarding QCDR measure licensing by supporting our sign-on letter which will be sent for your review within the next two weeks.

The broad policy goal behind CMS’ proposal to force measure sharing apparently was to encourage performance measure harmonization and reduce duplication across users. PCPI conference participants pointed out that forcing measure developers to bear the considerable cost without control over who uses their measures and how could have the opposite effect.


In addition to degrading measure integrity and the reliability of reported results due to lack of uniform use, forced measure sharing might actually encourage measure proliferation by encouraging development of very narrow measures that would have limited utility beyond their developers. This would undercut CMS’ push for broader, more meaningful, harmonized measures. The limited utility of narrow measures might also discourage expert specialty societies from developing measures or even sponsoring QCDRs, leaving the field to less-qualified EHR providers – again undercutting the goal of developing innovative, clinically meaningful measures with the potential to measurably improve care.


Better alternatives


Conference participants suggested several alternate approaches that would encourage measure harmonization without harming developers and users. These include:


  • Create easily searchable database of draft, existing and proposed QCDR measures by use and specifications

  • Foster early collaboration among all potential stakeholders in measure development

  • Inform CMS early of intent to develop measures, including indications for use and likely specifications

  • Require QCDRs to harmonize existing and proposed measures through expert panels representing stakeholders

  • Create standard licensing agreement for use of measures including reasonable fees to measure developers and maintainers


Help PCPI take the next step


Participants saw PCPI as a valuable resource for developing consensus among stakeholders for achieving greater measure harmonization. Steps the participants recommended include:


  • Convening stakeholders to refocus measure development on broader, more meaningful measures, to reduce the time and expense of measure development, and to assess and respond to CMS proposed rules in timely manner

  • Developing tools for harmonizing measure development, including a framework for harmonizing existing and future measures, and to provide access to PCPI information on existing and proposed measures and specifications

  • Advocating for CMS funding to support QCDR measure development, which is currently an unfunded mandate

  • Advocating consensus recommendations to CMS in joint letter from PCPI and member societies, and support consistent messaging by member societies


Our next steps are to send CMS a joint sign-on letter summarizing conference findings (December 2018) and to host a webinar to further discuss measure harmonization issues facing QCDRs (January 2019). Please stay tuned for the invitations to participate in these activities.

We look forward to your collaboration with us as we work on these vital efforts to improve health service quality and patient outcomes.

For more information on these efforts, please feel free to contact us at


About The PCPI Foundation

Founded in 2000 by the AMA and independent since 2017, The PCPI Foundation is a national leader in developing and maintaining clinical quality measures, clinical registry development and clinical quality improvement. Our members include more than 60 physician specialty and allied health profession societies, as well as patient advocacy, business and health system groups, and health IT and insurers. Dedicated to optimizing patient health outcomes, PCPI engages physicians, clinicians and key stakeholders to improve care through integrated performance measurement and clinically rich data to address shared health care quality challenges.


For more information on PCPI’s mission, activities and member benefits, visit

Our Members

353 N. Clark St. Suite 1400-a, Chicago, IL 60654 | Phone: 312-757-PCPI | General Email: