ASN Recommends Endorsement of New NQF Measures, With Caveats

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Responding to a request for comment from the National Quality Forum (NQF), ASN recently submitted recommendations for endorsement of 11 newly proposed measures for end stage renal disease (ESRD) care.

In its “Draft National Voluntary Consensus Standards” report, NQF recommended 11 measures for endorsement as voluntary consensus standards suitable for public reporting and quality improvement (Table 1). ASN was represented on the NQF Steering Committee that developed the proposed measures by Jeffrey Berns, MD, FASN, of the University of Pennsylvania School of Medicine. Berns was joined on the steering committee by 19 other ESRD community stakeholders, including nephrologists, patient representatives, and National Institute of Diabetes, Digestive, and Kidney Disease staff.


Based on the currently available data, ASN generally supported NQF’s 11 recommendations. However, ASN called attention to deficits on several measures and urged NQF to address these concerns as it finalizes the report. In particular, ASN noted that at this time, scant high-quality evidence exists to support the majority of the measures. As such, developing these new performance measures based on intermediate outcomes and retrospective observational studies will not necessarily improve care for patients with ESRD. Indeed, such measures could potentially lead to unintended adverse consequences or increased costs of care without improving meaningful, patient-centered outcomes. In the future, these measures should be replaced by new measures as scientifically validated performance targets are developed, ASN said.

ASN also noted that national voluntary consensus quality measures endorsed by NQF could potentially be used by the Centers for Medicare and Medicaid Services (CMS) as measures in the ESRD Quality Incentive Program (QIP). Although ASN generally supported the measures, the society conveyed reservations about their suitability for a financially incentivized measure owing to the insufficiency of scientifically validated evidence. ASN emphasized that any new measures CMS considers for the QIP must be subjected to rulemaking with a public comment period—even if the measures are endorsed by the NQF.

The National Quality Forum is a nonprofit organization whose mission is to improve the quality of American health care by endorsing national consensus standards that organizations can use for measuring the quality of their care and publicly reporting. While the NQF does not have any authority to make providers report or track the measures it endorses, CMS and other health care organizations often use NQF-endorsed measures when developing goals or programs for performance improvement.

ASN will continue to interact with NQF and monitor progress as the organization moves toward finalizing new consensus measures. To read ASN’s comments to NQF, visit ASN’s policy webpage at