The AGS has been active in measure review and development through participation in a number of partnerships and collaborations.
Our Position
As our health system continues to shift towards reimbursing providers based on the quality rather than the quantity of care they provide, we must ensure that measures used to evaluate healthcare performance take into account the unique healthcare needs of older people, as well as the challenges providers face when promoting health, independence, and well-being in light of particularly complex care needs.
Our Work in This Area
- Comments on Alzheimer’s Association's Use of Blood-based Biomarkers in the Diagnostic Workup of Alzheimer’s Disease Within Specialty Care CPG (May 22, 2025)
- Comment Letter to AHRQ on Diagnostic Excellence Measurement RFI (February 13, 2025)
- Comment Letter to CMS on Revisions to MIPS Geriatrics Specialty Measure Set for PY 2026 (January 31, 2025)
- Comments on Aging in the United States: A Strategic Framework for a National Plan on Aging (September 13, 2024)
- Comments on FDA Draft Guidance for Industry on Early Alzheimer's Disease: Developing Drugs for Treatment (June 10, 2024)
- Letter to FDA on PCNS Drugs Advisory Committee Review of Eli Lilly's Drug Donanemab for Alzheimer's Disease (June 7, 2024)
- Comment Letter to CMS on Revisions to MIPS Geriatrics Specialty Measure Set for PY 2025 (February 2, 2024)
- Comments on Revised Criteria for Diagnosis and Staging of Alzheimer’s Disease: Alzheimer’s Association Workgroup (November 16, 2023)
- Comments on Discrimination on the Basis of Disability in Health and Human Services Programs Proposed Rule (November 13, 2023)
- Comments on CMS Proposal to Revise Minimum Staffing Standards for Long-Term Care (November 6, 2023)
- Comments on Draft NIA-AA Revised Clinical Criteria for Alzheimer's Disease (August 16, 2023)
- Letter to the Architectural and Transportation Barriers Compliance Board on Standards for Accessible Medical Diagnostic Equipment Proposed Rule (July 24, 2023)
- AGS Supports CMS Decision to Require Real-World Data for Monoclonal Antibodies (July 11, 2023)
- Letter to CMS on Geriatrics Measures for CY 2024 Inpatient Prospective Payment Systems Proposed Rule (June 9, 2023)
- Letter to HHS on the Physical Activity Guidelines Midcourse Report for Older Adults (March 10, 2023)
- AGS Supports CMS Decision to Maintain Current National Coverage Determination for Monoclonal Antibodies
- Comment Letter to CMS on Revisions to MIPS Geriatrics Specialty Measure Set PY 2024 (February 13, 2023)
- Letter to FDA on Review of Eisai's Drug Lecanemab for Alzheimer's Disease (December 22, 2022)
- Comment Letter to AHRQ on Person-Centered Care Planning for Multiple Chronic Conditions (November 15, 2022)
- Comments to AHRQ Evidence-Based Practice Center for a New Evidence Review (June 3, 2022)
- Comment Letter to CMS on Revising Nursing Home Staffing Requirements (June 10, 2022)
- Comment Letter on the draft Centers for Disease Control and Prevention Clinical
Practice Guideline for Prescribing Opioids (April 11, 2022) - Comment Letter to ASPR on the 2023-2026 National Health Security Strategy (March 11, 2022)
- Comment Letter to CMS on Revisions to MIPS Geriatrics Specialty Measure Set
- Comment Letter on Proposed National Coverage Determination for Monoclonal Antibodies Directed Against Amyloid for the Treatment of Alzheimer’s Disease(February 10, 2022)
- Comment Letter to ICER on Assessment for Beta-Amyloid Antibodies for Alzheimer’s Disease (January 18, 2022)
- Letter to HHS on the Physical Activity Guidelines for Older Adults (December 7, 2021)
- Joint Society Letter to CMS on National Coverage Analysis for Monoclonal Antibodies Directed Against Amyloid for the Treatment of Alzheimer’s Disease (November 22, 2021)
- Joint Society Letter to FDA on Aducanumab Label (September 30, 2021)
- Comments to CMS on National Coverage Analysis for Monoclonal Antibodies Directed Against Amyloid for the Treatment of Alzheimer’s Disease (August 11, 2021)
- Joint Society Letter to CMS on Beta Amyloid PET Coverage (July 19, 2021))
- AGS Comments on ABMS Draft Standards for Continuing Certification (July 8, 2021)
- Letter to FDA on Review of Biogen’s drug Aducanumab for Alzheimer’s disease (June 2, 2021)
- Letter to Office for Civil Rights on Proposed Modifications to HIPAA Privacy Rule (May 6, 2021)
- Letters to President Biden and Congressional Leadership Outlining AGS Policy Priorities for New Administration and Congress (February 5, 2021)
- AGS Additional Comments to Senate Finance Subcommittee on Health Care Regarding Alzheimer's Disease and Related Dementias (July 23, 2020)
- AGS Comments to Senate Finance Subcommittee on Health Care on Improving Care for Alzheimer’s Patients (March 17, 2020)
- Letter to CMS on CY 2020 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule (September 27, 2019)
- Letter to Senate Special Committee on Aging on Falls Prevention (July 2, 2019)
- Letter to House Committees on Ways and Means and Energy and Commerce on Medicare Part D Improvements (June 6, 2019)
- Letter to Senate Health, Education, Labor, and Pensions Committee on Lower Health Care Costs Act of 2019 Discussion Draft (June 5, 2019)
- AGS Comments to the U.S. Department of Health and Human Service on Pain Management Best Practices: Updates, Gaps, Inconsistencies, and Recommendations Draft Report (April 1, 2019)
- Letter to VA on Veterans Community Care Program Proposed Rule (March 25, 2019)
- Letter to VA on Urgent Care Benefit Proposed Rule (March 1, 2019)
- Letter to Senate Health, Education, Labor, and Pensions Committee on Reducing Healthcare Costs and Improving Care (March 1, 2019)
- Letter to CMS on Revisions to MIPS Geriatrics Specialty Measure Set (February 11, 2019)
- Letter to CMS on CY 2019 Physician Fee Schedule and Quality Payment Program Proposed Rule (September 10, 2018)
- Letter to CMS on New MIPS Specialty Measure Set for Geriatrics (February 9, 2018)
- Letter to CMS on Revision to Nursing Home Quality Measure (January 24, 2018)
- Letter to CMS on Innovation Center New Direction RFI (November 20, 2017)
- Letter to CMS on Patient Relationship Categories and Codes (January 6, 2017)
- Letter to CMS on MACRA Final Rule (December 29, 2016)
- Letter to CMS on Bundled Payment Models for Cardiac and Orthopedic Care Proposed Rule (October 3, 2016)
- Letter on CY 2017 Physician Fee Schedule Proposed Rule (September 6, 2016)
- Letter to CMS on MACRA Proposed Rule (June 27, 2016)
- Letter to CMS on Changes to Medicare Part D for CY 2017 (March 4, 2016)
- Letter to CMS on Episode Groups RFI (March 1, 2016)
- Letter to Senate Finance Committee on Chronic Care Policy Options (January 26, 2016)
Working in Partnership
- Battelle’s Partnership for Quality Measurement (PQM)
- National Quality Forum (NQF)
- National Committee for Quality Assurance (NCQA)