Thank you for your question. The measure uses the industry-standard terminology of “Administrative Gender” to include members with administrative gender female. The current exclusion is designed to ensure that people without sufficient breast tissue to recommend routine screening be excluded from the measure as clinically appropriate. The measure steward, the National Committee for Quality Assurance, will consider this feedback for future iterations of the measure.

For the breast cancer screening measure, bilateral mastectomy is an exclusion for inclusion in the denominator. However, currently, there is not an exclusion for masculinizing top surgeries done in gender affirming care. These surgeries are not the same as bilateral mastectomy because there is a small amount of breast tissue left, but not enough to recommend mammograms. Our recommendation would be to create a top surgery exclusion for this measure.