ACP to CMS: Patient COVID-19 Vaccination Rates Inappropriate as a Performance Measure

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The National Quality Forum, which makes formal recommendations to CMS on performance measures, recently recommended against implementing the measure

Feb. 24, 2023 (ACP) — Recent advocacy by the American College of Physicians has led to recommendations against using patient COVID-19 vaccination rates as a measurement to grade physician performance.

In 2022, the Centers for Medicare & Medicaid Services proposed the new performance measure for federal health programs such as Medicare. ACP opposed the measure and reached out to CMS and the National Quality Forum, which makes formal recommendations to CMS about performance measures. Heeding input from ACP, the National Quality Forum released a revised list of recommendations on performance measures that advised against putting a COVID-19 vaccination-rate performance measure into effect. This is a major victory for ACP and our members.

Members of a CMS workgroup got quite an earful when they asked medical professionals about the idea of using patient COVID-19 vaccination rates as a measure to grade physician performance.

Most of the workgroup members did not support the measure and spoke strongly against it.

Dr. Jason Goldman, a member of the ACP Board of Regents and an internal medicine physician in Florida, participated in the workgroup. Goldman was very engaged. As he recalled, the staff members managing the workgroup told him: “Dr. Goldman, we know you don't approve of this measure; we get it, we understand. Okay. How can we make it better?” His answer: “You can't. You can't put lipstick on a pig, and you can't make this look better. It's a bad idea.”

Performance measures, which aim to gauge the quality of medical care, have become routine components of the health care system. “It's mandatory to report some measures, and some are voluntary,” Goldman said. “The measures are then used to rate a physician's quality and can affect their Medicare reimbursement.”

CMS worked with outside contractors, to seek input on COVID-19 measures in this case, it was the National Committee for Quality Assurance that assembled a workgroup to gather perspectives from physicians and other experts. “The goal was to determine whether this measure can be implemented,” Goldman said. “What are the logistics? What's the validity of it?”

“The problem with judging physicians by the percentage of vaccinated patients is that doctors simply do not have control over that number,” he said. Instead, the political environment and other factors affect the number of people who are vaccinated.

“You're dealing with a vaccine that's politically charged. For some people, vaccines in general are controversial,” Goldman explained. “How do you tell physicians that they're going to be punished for not getting their patients vaccinated when they're in a state where they're discouraging people to get vaccinated?”

In addition, “reporting to the government information that they already have about vaccination rates is just a waste of physicians' time,” he said. “And there's no evidence that reporting on vaccination rates will improve the uptake.”

There is another complication: Vaccination guidelines continue to evolve. “How do you hold a physician to a standard when we keep changing? We felt there was no validity to having this as a reporting measure at all,” Goldman said.

Fortunately, he said, “through the work of ACP, we've been able to stop or disqualify some problematic measures like these and take them out of circulation.”

ACP continues to review new performance measures as they are proposed and, as always, will advocate for the best strategies to put the needs of patients and physicians first.

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Back to the February 24, 2023 issue of ACP Advocate