The feedback from public comment was positive, with 87 percent of the comments either supporting the measures or supporting them with modifications (Appendix D). The majority of the comments touched on issues that had been discussed by the project team and the TAG during the measure development process, such as expanding the denominator in the physical health screening measures to include anyone with SMI, including measures evaluating psychosocial care, and lowering the age of eligibility for the measures.
Some comments raised concerns about the accountability for measures; for example, several commenters expressed concern that offering cervical cancer screening was out of scope for psychiatrists and psychologists. The project team believes this is a misunderstanding on the part of providers. The state, not the provider, is the unit of accountability for these measures. Further, given the push toward integrated care, states may be held accountable for the coordination of care between medical and mental health settings. This may include encouraging mental health professionals, including psychiatrists, to inquire about these services and potentially refer for such services. This is no different from the expectation that psychiatrists address the metabolic condition of patients in their care. Therefore, we propose retaining screening measures.
We received technical comments concerning coding of medication lists, including HbA1c tests as part of the diabetes screening measure, and methods to determine use of injectable antipsychotic medications. The project team carefully considered these concerns when finalizing measure specifications.
The measure that received the least support from public comment was Emergency Department Utilization for People with Schizophrenia. Feedback centered on the measure being non-action-oriented because it included non-mental health admissions. Comments also focused on the measure possibly encouraging overuse of emergency servces. Based on this feedback, the broad measure of Emergency Department Utilization was not submitted for NQF endorsement.