Comment on CMS-2026-2377-0002

This comment concerns the following proposed measures in Appendix A: A.2. Functional Improvement for Patients with Neck Impairments A.3. Functional Improvement for Patients with Upper Extremity Impairments A.4. Functional Improvement for Patients with Back Impairments A.5. Functional Improvement for Patients with Lower Extremity Impairments A.6. Functional Improvement for Patients with Knee Impairments These measures evaluate whether adult patients achieve risk-adjusted Predicted Moderate Clinical Improvement, or P-MCI, using PROMIS Physical Function or an approved legacy patient-reported outcome measure. We support patient-reported outcomes and meaningful measures of functional improvement. However, we have significant concerns regarding the feasibility, transparency, and public accessibility of these measures. The published descriptions do not provide the complete methodology needed to calculate P-MCI. Missing information appears to include the prediction equation, model coefficients, risk-adjustment variables, scoring thresholds, missing-data rules, and technical specifications required for an independent registry, EHR vendor, or practice to calculate and validate the measures. Based on currently available information, organizations may be required to use platforms operated by Limber Health or Patient360 to perform the P-MCI calculation. This could require practices and registries to contract with a measure steward, purchase access to a proprietary platform, create additional interfaces, or transmit patient-level information to another vendor. Independent registries should be able to collect, calculate, validate, and report quality data without being required to use a competing registry or proprietary platform. The measures raise several concerns: The P-MCI methodology is not publicly available in sufficient detail for independent implementation. Registries may be unable to calculate or validate the measures without a licensing agreement. Practices may incur additional financial, technical, and administrative burdens. The lack of public calculation specifications prevents transparent auditing and reproduction of results. Smaller practices may be unable to report the measures. It is unclear how scores from different approved instruments should be converted or incorporated consistently into the same performance calculation. For a measure to be publicly available under MIPS or through a QCDR, all reporting entities should have equitable access to the information required for implementation. Reporting should not depend on purchasing services from or transferring clients to a measure steward. We recommend that CMS provide, or require the measure stewards to provide, a validated and publicly available crosswalk for all approved assessments. The crosswalk should explain how scores are converted, normalized, and interpreted to determine whether P-MCI was achieved. It should include scoring ranges, conversion methodology, validation evidence, assessment-version rules, and sample calculations. CMS should also require publication of the complete P-MCI methodology, including the risk-adjustment model, coefficients, required data elements, episode definitions, missing-data rules, and numerator and denominator logic. Alternatively, CMS could provide a publicly accessible calculator or API that any reporting entity may use without enrolling in the Limber Health or Patient360 QCDR. If the methodology and crosswalk cannot be made publicly available and independently implemented, we recommend that CMS not finalize these measures as broadly available reporting options. A measure should not be publicly reportable when its core calculation is accessible only through proprietary platforms controlled by its stewards. We request clarification regarding how CMS will ensure that independent registries and practices can calculate, validate, and report these measures without being required to use the Limber Health or Patient360 platforms. Thank you for considering these comments.