Comment on CMS-2026-1256-0002
Center to Advance Palliative CareOpposeAdvocacy
Summary: The Center to Advance Palliative Care (CAPC) opposes the proposed adoption of the Advance Care Planning Electronic Clinical Quality Measure, arguing that there is insufficient evidence that such planning improves medical decision-making. They express concerns that the measure creates a documentation burden for clinicians and may lead to "check-box" compliance rather than meaningful patient care, and they suggest alternative measures focused on communication skills and patient experience.
The Center to Advance Palliative Care (CAPC) is a national organization dedicated to improving quality of life and strengthening care delivery for people living with serious illness, and their caregivers. We offer several cautions, together with alternative recommendations, for Section IX B 1, Proposed Adoption of the Advance Care Planning Electronic Clinical Quality Measure.
Please see the letter attached.