Person-Centered Care and the Move to Digital Measurement

September 6, 2022 · Andy Reynolds

Driving innovation to promote person-centered care was one topic in a recent CMS request for information about Medicare Advantage.  

 NCQA’s response emphasized data exchange and the move to digital measurement. Here’s a summary of what we said.   

 6 Observations on Digital Measurement

1. Agree on Vision: We are encouraged by CMS’s commitment to requiring that all quality measures be reported as digital quality measures.

   
   To do our part in the new world CMS envisions, NCQA has invested in building a digital quality ecosystem to create more efficient data collection and reporting, and better accountability at all levels.

2. Alignment in Action: Our first Digital Quality Solutions Pilot will move the industry toward realizing the full potential of digital quality measures. The pilot can also be a model for CMS’s measure calculation tools—as outlined in the agency’s Digital Quality Measurement Strategic Roadmap.
   
   
3.  Incentives for Switching to Digital: CMS can ease the transition to digital measurement by incenting and rewarding organizations that go digital. For Medicare Advantage, CMS should consider bonus payments for digital reporting through the Star Ratings system or other programs.
   
   
4. Advancing Interoperability: To help digital measurement spread, we suggest CMS fund efforts to advance data interoperability and focus on making tooling and guidance available.
   
   
5. Mapping Among Data Models: We like Georgia Tech’s Fast Healthcare Interoperability Resources and Observational Medical Outcomes Partnership (OMOPonFHIR), which developed tools to convert from one data model to another.

   
   OMOPonFHIR is an example of advancing data standards in a way that’s not “one-size fits all.”

   Mapping among a variety of data models can:

   • Accelerate progress.
   • Provide the most value.
   • Ease the burden of transitioning to digital measurement.
     
     
6. Incentives for Standardized Data Exchange: We encourage CMS to continue to incentivize standardized data exchange under the Trusted Exchange Framework and Common Agreement (TEFCA) through other CMS programs and value-based payment models. This will enhance the industry’s ability to extract quality measurement data from health information exchanges and other sources besides EMRs.

We Differ on Measure-Weights in Stars

Our public comment response also explained why we disagree with the recent change that doubled the weight of patient experience, complaints and access measures in the Medicare Advantage Stars Ratings methodology.

Recent moves by NCQA and others to stratify quality data by race and ethnicity will shine a light on inequities. But reducing clinical measures’ importance may mean health plans have less incentive to close care gaps.

In making the case for process measures, we noted:

• Process measures, such as evidence-based cancer screening, are tied to outcomes.
• Process and intermediate outcome measures improve health, health plan performance and cost.
• Measures related to wellness, prevention and chronic disease management can improve quality of life and save money.

For more on measure weighting in MA Star Ratings, see what we told Becker’s Payer Issues.

A Good Start on Personalization

NCQA applauds CMS’s efforts to:

• Test a web-based version of the CAHPS survey. (We go back a long way with CAHPS.)
• Test new survey topics that address language, experience with remote care and perceived discrimination.
• Collect sexual orientation and gender identity data—something we’ve started doing with HEDIS.

We urge CMS to do more to incorporate patient voice in the Star Ratings. Moving to next-generation digital measurement offers the chance to:

• Reduce reporting burden.
• Improve the accuracy and usability of measures and ratings.
• Tailor measurement to what matters to patients and caregivers.

A digital approach to patient experience can:

• Improve identification of populations from whom feedback is most needed (e.g., people with multiple chronic conditions and those harmed by social risks).
• Improve response rates compared to today’s “snail mail” surveys.
• Provide more targeted and actionable results.

To further improve the holistic measurement of patient experience, we also encourage CMS to explore:

• Measuring experience across care settings, such as care in people’s residences. (Care at home came up a lot at  Quality Talks 2022, especially talks by Sami Inkinen of Virta Health and Diana Isaacs of the Cleveland Clinic.)
• Adding person-centered measures to Star Ratings. (Person-centered measures are an important frontier we are exploring.)

Read our entire CMS public comment response.