Clinical Quality Measures for Stage 2 and Stage 3 of Meaningful Use

David Lansky
Quality Measures Workgroup
Office of the National Coordinator

Dear Dr. Lansky:

The National Coalition for Cancer Survivorship (NCCS) appreciates the opportunity to offer comments on the clinical quality measure concepts for stage 2 and stage 3 meaningful use and to recommend specific measures consistent with certain of the measure concepts.  The goal of NCCS is the delivery of quality cancer care to all people touched by cancer, and we are engaged in public policy and quality improvement initiatives to advance that goal.   Cancer survivors will be well-served by the development of solid clinical quality measures to guide the use of health information technology, and we are pleased to offer comments early in the measures development process.

The core NCCS recommendation is a measure of patient receipt of a cancer care plan at several critical junctures across the continuum of cancer care: at the point of diagnosis and decision-making regarding initial treatment, at any time when there is a significant change in condition or treatment, and at the end of treatment and beginning of survivorship.  The core elements of the plan would be: 1) all elements of active treatment and symptom management, 2) information about the goals of treatment, 3) recommendations regarding appropriate palliative care across the continuum of care, and 4) collaborative development of the plan through a decision-making process involving provider and patient.  The treatment details in the plan offered to survivors would focus on long-term monitoring and appropriate intervals for follow-up care.

We believe the recommendation of a measure of receipt of a cancer care plan meets the criteria established by the Quality Measures Workgroup.  The NCCS-recommended care plan measure is HIT-sensitive because a care plan can be easily built into electronic health record systems; demonstrates preventable burden, especially by reducing the burden of long-term and lasting side effects of treatment in survivors; assesses health risk status and outcomes in patients from the moment of diagnosis and throughout survivorship; and is longitudinal because it supports the assessment of patient-focused episodes of care.  We also believe the measure is parsimonious in two ways.  First, an essential feature of the cancer care plan is its facilitation of the coordination of care; by setting out a plan of care, the cancer care plan applies across multiple providers and care settings and also addresses co-morbidities that may affect cancer patients.  Second, the cancer care plan measure is parsimonious by achieving the goals of several measure concepts.  The measure of receipt of a cancer care plan meets the goals of the measure concepts related to patient preferences and shared decision-making, effective care planning, care transitions, and appropriate and timely follow-up.

Significant progress has been made in the development of cancer care planning templates and educational materials for cancer care professionals, and the American Society of Clinical Oncology (ASCO), through its Quality Oncology Practice Initiative, has developed a measure for development of cancer care plans.  We recommend that the measures adopted for HIT utilization be consistent with, and build on the intellectual and practical work undertaken to develop, cancer quality measures that are currently being used effectively to enhance overall care quality.

NCCS recommends serious consideration of a measure that would assess communication with cancer survivors about healthy lifestyle behaviors, with a focus on smoking cessation and body mass index.  We understand that the measure concept related to healthy lifestyle behaviors is intended to encompass a broad population of Americans and is not intended to be focused on specific sub-populations.  However, because of the special risks that smoking and unhealthy body mass may pose to cancer survivors, we recommend a measure that would assess health professional communication with survivors regarding these risks.

NCCS is aware of several ongoing initiatives to encourage clinician adherence to clinical practice standards, efforts that are consistent with one of the measure concepts.  These efforts are being undertaken in part as research efforts, to assess the best means to ensure such adherence.  The development of measures to assess adherence to practice guidelines should be informed by these ongoing efforts.  We also believe that adherence to practice standards can also be encouraged by the development of cancer care plans that set out the goals of treatment and define the standards of care at the beginning of the treatment process, as defined above.

We appreciate the opportunity to comment on the measure concepts and to offer specific measures consistent with the general concepts.


Thomas P. Sellers
President & CEO
National Coalition for Cancer Survivorship

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