Re: Request for Information on the Use of Clinical Quality Measures (CQMs) Reported
under the Physician Quality Reporting System (PQRS), the Electronic Health Record
(EHR) Incentive Program, and Other Reporting Programs
Dear Ms. Tavenner,
On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological
Surgeons (CNS), we appreciate the opportunity to comment on the Center for Medicare & Medicaid
Services’ (CMS) request for information (RFI) on the Use of Clinical Quality Measures Reported under
the Physician Quality Reporting System (PQRS), the Electronic Health Record (EHR) Incentive Program
and Other Reporting Programs. Organized neurosurgery is encouraged by the agency’s efforts to
address physician quality measurement reporting and improvement in a manner that is more relevant
and meaningful to clinicians and patients.
Summary of Comments
- Neurosurgery is currently developing tools to help neurosurgeons adopt and incorporate systems of
learning into their practice, which will improve quality of care, provider workflow, patient safety and
efficiency. To meet the growing need for tools to measure and promote quality care, we have
launched the National Neurosurgery Quality and Outcomes Database (N2QOD). In addition, the
American Board of Neurological Surgery is incorporating clinical data collection into its
Maintenance of Certification (MOC) program; thus providing a further avenue for ensuring the
quality of care provided by neurosurgeons
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