On behalf of SSM Health, based out of St. Louis, Missouri, we would like to respectfully submit comments on the proposed PC-02 Cesarean Birth eCQM. Our clinicians sent a few comments/questions outlined below for your consideration during this measure proposal period:

1.) Our team urges CMS to not completely remove the PC-02 chart-abstracted measure to be replaced by the PC-02 eCQM. Currently, documentation for this information is found in the patient's history and physical (H&P) documentation within our organization's electronic health record. The H&P is a document that does not have extractable fields within it, therefore, we would not be able to obtain number of previous live births electronically for an eCQM.
2.) Can consideration be given to the Maternal Fetal Medicine (MFM) Specialist recommendations for delivery at less than 39 weeks? There is no obstetrician that will not consider and follow the recommendation of the MFM. Often, the recommendation is made and does not "fit" into one of the existing lists of considitions that might possibly justify early delivery.
3.) Can consideration be given to the patient with a previous still birth at 39 weeks gestation? In a subsequent pregnancy, it is extremely difficult to tell the patient that she cannot deliver before 39 weeks with that history of tragedy. More often than not, the patient would want to deliver before the 39 weeks date as a failsafe measure to avoid another stillbirth.
4.) Can consideration be given to other elements of the biophysical profile besides heart rate? If the fetal breathing movement or fluid level are scored zero, the total BPP score is lowered. Many providers would want to move forward with delivery based on these warning signs.
5.) When the gestational age is unknown due to no prenatal care and only estimated in the record, can this be an exclusion? There is value, but to fail the measure based on an estimate seems inappropriate.

Thank you for the opportunity to submit feedback on the proposed PC-02 Casearean Birth eCQM.