NCQA’s Policy Recommendations to the Trump Administration

April 15, 2025 · NCQA Communications

The fragmented U.S. health care system makes it challenging for people to navigate treatment and receive high-quality care. Advancements in quality measurement, care integration and interoperability are essential for creating a more efficient and accountable health care system.

NCQA developed recommendations for the Trump administration in three core areas.

1. Implementation of value-based care models that prioritize care integration.
2. A strong digital health infrastructure that facilitates seamless data exchange, promotes adoption of digital quality measures and maximizes the full potential of interoperable health care data.
3. Integration of behavioral and physical care and removal of barriers to behavioral health and substance-use disorder treatment.

Below is a summary of our recommendations.

Optimize Value-Based Care and Alternative Payment Models

Patients who seek care—especially the 133 million people living with chronic disease—encounter poorly coordinated, redundant services that create unnecessary burden. Payers often exacerbate the problem with care management initiatives and administrative barriers that cause more fragmentation. Clinicians spend hours documenting data for administrative purposes, which pulls them away from providing care.

NCQA Recommendations

Prioritize the patient experience by removing administrative barriers and burden. Modernizing payment structures by accelerating the transition to value-based care could help eliminate the disjointed, costly care many people experience in the fee-for-service model.

• Commit to helping ensure that all Medicare beneficiaries are in value-based care arrangements by 2030.
• Create payment models that prioritize integration through technology and dynamic care plans. For example:
  • Focus on conditions and procedures with significant cost variability, large patient volumes and clear opportunities to reduce complications, hospital readmissions and unnecessary utilization.
  • Require collaboration in developing AI-driven models targeting problematic conditions and procedures.
  • Adopt AI-powered, evidence-based, shared care plans to build trust and empower patient choice.
• Introduce Medicare Advantage Star Ratings metrics that promote standardized data exchange between health plans, care delivery networks and patients.
• Prioritize more effective use of patient-generated data, including person-reported outcome measures, which offer valuable insights for improving health outcomes.

By expanding value-based payment arrangements, we can invest in solutions to better manage chronic diseases, align incentives to promote health and wellness and reduce health care costs.

Create a Lasting Digital Health Infrastructure

Private and government investments have increased the availability of electronic health data, but the use and exchange of these data to support health care innovation—and reap the benefits of investments—is hindered by misaligned policy incentives and payment programs. Quality measurement programs rely on labor-intensive, fragmented, inconsistent systems with incomplete data.

Policy groundwork was established through the CMS interoperability rules (CMS-0057), the United States Core Data for Interoperability Plus (USCDI+) and the efforts of standard-setting communities, but stronger support from the administration can drive industry implementation, accelerate exchange of health data and spur health care innovation.

NCQA Recommendations

Create a clearer framework for a national digital health data ecosystem where all participants in care can innovate and benefit, building on existing mandates for FHIR^® APIs, USCDI and industry innovation in patient-generated data. This is a critical opportunity to reduce care fragmentation and lower costs—and to improve health care for all Americans.

• Expedite adoption of a digital quality measure reporting architecture.
• Develop a comprehensive health care data quality framework that fosters confidence, transparency and collaboration, and supports a fully digital health data exchange ecosystem.
• Accelerate alignment with the CMS Universal Foundation across HHS quality reporting and value-based payment programs.
• Clarify how the USCDI+ Quality dataset will interact with regulations to achieve true interoperability of quality data.
• Update the existing CMS Digital Quality Roadmap.

With national interoperability frameworks now leveraging HEDIS exchange, we look forward to collaborating with the administration to ensure the integrity and trustworthiness of data used across the nation’s health care system.

Address the Behavioral Health Crisis

Over 20% of American adults live with mental illness, and more than 5% experience serious mental illness. Recent estimates place the resulting economic strain at over $280 billion. The surge in demand for behavioral health services overwhelms state and county behavioral health systems, pushing more patients to seek services in settings that may not be adequately equipped to support them.

NCQA Recommendations

Measurement of quality in behavioral care is inadequate and is falling behind other health services, due to limited investment. We must intensify our efforts to address this crisis through increased funding for quality improvement, national standards and technological advancement.

• Collaborate with Congress to appropriate funds to incentivize adoption of certified EHRs by behavioral health providers.
• Expand access to medication for opioid use disorder as first-line, evidence-based treatment.
• Fund the creation of a quality measures cascade framework for substance-use disorder care with quality standards at every appropriate level of care.
• Require independent, third-party accreditation for SAMHSA’s CCBHC certification to ensure accountability and transparency.
• Support development and testing of behavioral health network adequacy measures for inclusion in the Medicare Advantage Star Ratings and other value-based payment programs.

We look forward to collaborating with the Trump administration to advance quality measurement for behavioral care and create a more cohesive health care system that connects behavioral and physical health to improve outcomes.

Learn More

Visit our website to download the full recommendations.