Appendix F – Public Comments AHRQ Response

September 29, 2014

Doris Lefkowitz,
Reports Clearance Officer
Agency for Healthcare Research and Quality
540 Gaither Road
Rockville, MD 20850

Dear Ms. Lefkowitz:
On behalf of the Council of Academic Family Medicine, which includes the North American
Primary Care Research Group (NAPCRG), the Society of Teachers of Family Medicine(STFM),
the Association of Departments of Family Medicine (ADFM), and the Association of Family
Medicine Residency Directors (AFMRD), we appreciate the opportunity to respond to the Agency
for Healthcare Research and Quality’s (AHRQ) July 30th Federal Register request for comments
on your proposed information collection project “Care Coordination Quality Measure for Patients in
the Primary Care Setting (CCQM-PC).”
We have communicated to AHRQ in previous letters that transforming primary care practices to
be effective medical homes for our patients should be a key priority – and one that can only be
accomplished with studies in the primary care environment, so we applaud the work the agency is
doing in this endeavor.
One of the areas not addressed by AHRQ in this project that makes a significant difference in care
coordination is payment. If a practice is receiving a PMPM for care coordination efforts, it is more
likely to have extra support, in the form of more staff, to complete care coordination functions. This
can make a significant difference on how much care coordination can be done in an office and
needs to be factored into the evaluation. It also should be factored into the assessment of whether
the survey is realistic for all participating in the project.
Researchers and clinicians are looking for meaningful ways to measure coordination. We have
some concern that the 25 minutes identified by AHRQ as needed to complete the 102 item survey
may be too optimistic. In terms of the sampling AHRQ plans on using, the notice speaks of
recruiting 30 practices “of different types and ownership configurations” to provide a patient
sample to AHRQ’s contractor. We would recommend that AHRQ’s selection criteria include a
requirement that at least two practices from each of the following three areas be included in the
sample: federally qualified community health centers, health professional shortage areas, and
rural areas. In addition, we would like to ensure that the sample of practices include a mix of those
with and without care coordination payments.

Thank you again for the opportunity to comment on the Care Coordination Quality/Measure for
Patients in the Primary Care Setting project.
Sincerely,

Sam Cullison, MD
President
Society of Teachers of Family
Medicine

Rick Glazier, MD
President
North American Primary Care
Research Group

Paul James, MD
President
Association of Departments of
Family Medicine

Todd Shaffer, MD, MBA
President
Association of Family Medicine
Residency Directors

Reid B. Blackwelder, MD, FAAFP
President
American Academy of Family
Physicians