NCQA Comments on ASTP’s Draft USCDI+ Quality Dataset

October 15, 2024

Micky Tripathi, PhD, MPP
Assistant Secretary for Technology Policy
U.S. Department of Health and Human Services
330 C Street SW, 7th Floor
Washington, DC 20201

Dear Dr. Tripathi:

The National Committee for Quality Assurance (NCQA) thanks ASTP for the opportunity to provide feedback on the USCDI+ Quality Dataset.

NCQA is a private, 501(c)(3) not-for-profit, independent organization dedicated to improving health care quality through our Accreditation and measurement programs. We are a national leader in quality oversight and a pioneer in quality measurement. Leveraging our strengths as a trusted third party, we are committed to helping organizations navigate the challenges associated with moving toward an equitable health care system. Our mission to improve the quality of health for all Americans, with a focus on health equity and support for meaningful value-based payment models, propels our daily work.

NCQA applauds ASTP efforts to develop comprehensive datasets to support quality use cases and we thank ASTP for including NCQA’s Healthcare Effectiveness Data and Information Set (HEDIS®) data element needs in USCDI+ Quality. We look forward to continuing to support this important initiative.

Data elements to add to USCDI+ Quality
We offer the below recommendations for additional data elements to be added to the USCDI+ Quality dataset. These data elements are used by HEDIS measures or necessary to support measures in active development.
1. Care Team Members Data Class
  1. Care Team Member Specialty: add to Quality V1
    1. Defined as the specific specialty of the practitioner (Vocabulary: Healthcare Provider Taxonomy). We recognize an element “Medical Specialty” has been added to the Encounter Information data class and recommend moving this element to the Care Team Member data class and adding the Healthcare Provider Taxonomy vocabulary if it is intended to capture the same concept as this proposed element.
2. Goals and Preferences Data Class
  1. Patient Goal Category: add to Quality Overarching
    1. Defined as the domain of the stated patient goal. Examples of goal categories include housing, physical function, behavioral, and social & role functioning (Vocabulary Standard: HL7 terminology, Goal Category).
  2. Date of Patient Goal: add to Quality V1
    1. Defined as when patient goal pursuit begins.
3. Health Status Assessments Data Class
  1. Depression Screening: add to Quality V1
    1. Create a distinct element for depressions screening, as included in USCDI+ Maternal Health dataset. Alternatively, ASTP may consider updating the Mental/Cognitive Status element definition to align to the USCDI v5 definition.
  2. Tobacco Use Status: add to Quality V1
    1. Defined as assessments of a patient’s tobacco use behaviors including use of smoke, vape, chew, or sniff tobacco products (Vocabulary: SNOMED CT and LOINC). Alternatively, ASTP may consider renaming/redefining the Smoking Status data element to include assessment of more comprehensive tobacco products beyond combustible products like cigarettes.
4. Medications Data Class
  1. Medications Dispensed: add to Quality V1
    1. Add a new element, as defined by the USCDI+ Public Health and Behavioral Health datasets.
  2. Date Medications Dispensed: add to Quality V1
    1. Defined as when the medication was handed over or given out.
5. Explanation of Benefits Data Class
  1. CPCDS elements: add to Quality Overarching
    1. We recommend adding Carin Blue Button CPCDS elements to support exchange of adjudicated claims information (without financial information), as proposed in USCDI by Carin Alliance. While NCQA believes these CPCDS elements should ultimately be added to USCDI, we support the addition to USCDI+ Quality in the interim. Adding CPCDS elements to USCDI and USCDI+ aligns requirements across payers and health IT, and will improve data sharing abilities across health plans and providers. We point ASTP to Carin Alliance USCDI submission and CPCDS-USCDI element crosswalk.
6. Cancer Care Data Class
  Add the following elements related to genomics to the Cancer Care Data Class (Quality Overarching) to support tracking of important genomics data elements for future inclusion in quality measures, as standards evolve. NCQA also recommended these elements for the USCDI+ Cancer dataset.
  1. Gene Studied
  2. Genomic Source Class
  3. Clinical Significance of Genetic Variation
Revisions to elements included in the USCDI+ Quality dataset
We offer the below recommendations for modifications to existing data elements to support HEDIS measure uses.
1. Advance Directive Observation: add SNOMED CT, CPT, ICD as appropriate vocabulary standards.
2. Alcohol Use: add SNOMED CT and ICD as appropriate vocabulary standards.
3. Coverage Type: Adjust the data element description and examples.
  1. As also proposed for USCDI, we recommend that coverage type should include product line (for example Commercial, Medicare, Medicaid), product (for example PPO, HMO, POS), and benefit (for example drug, mental health). Comprehensive, and hierarchical, coverage type information allows for utility of the data.
4. Diagnostic Imagining Report: Add SNOMED CT as appropriate vocabulary standard for the structured components of the report representing the clinical interpretation of the imaging study.
5. Discharge Summary Note: Update the required components included in the description.
  1. As also proposed for USCDI, we recommend the following components are required: practitioner responsible for the care, reason for hospitalization, diagnoses at discharge, procedures or treatment provided (including test results), current medication list, instructions for patient care post-discharge, and pending tests.
6. Sex Parameter for Clinical Use: add Gender Harmony Implementation Guide as an associated Implementation Guide.
  1. NCQA supports aligning to Gender Harmony guidance and recommends adding the Gender Harmony Implementation Guide as an associated Implementation Guide for the data element: https://hl7.org/xprod/ig/uv/gender-harmony/
Data elements included in the Quality Overarching use case but not the Quality V1 use case that should be added
NCQA identified two data elements included in the Quality Overarching use case that we recommend should be added to the Quality V1 use case:
1. Gestational Age
2. Estimated Date of Delivery
These Pregnancy Information data elements are critical pieces of data to define appropriate populations to measure and support maternal health and we use these elements across several HEDIS measures. Based on the availability of vocabulary standards and ability to exchange the data via FHIR US Core, we feel they are mature enough for the Quality V1 use case. These elements are also included in the USCDI+ Maternal Health and Public Health data sets, underscoring their importance.
Other general comments
1. NCQA recommends the USCDI+ datasets builds on the USCDI but do not include duplicative elements that are already in USCDI. Duplication of elements between USCDI and USCDI+ Quality may lead to difficulty keeping datasets aligned as updates are made and can cause confusion between datasets if there are periods of time with discrepancies. We believe creating the USCDI+ Quality dataset as a parsimonious set of elements critical for quality measurement that build on the USCDI will be most useful for the quality community.
2. NCQA recommends ASTP and other federal agencies provide clarification on if and how the USCDI+ Quality dataset will intersect with regulation. Defining a clear pathway for how USCDI+ datasets will be incorporated into regulation will support unlocking true interoperability of quality data.

Thank you for the opportunity to comment. We remain committed to working with ASTP to build a more equitable, sustainable and responsible American health care system. If you have any questions, please contact Eric Musser, Vice President of Federal Affairs, at (202) 955-3590 or at musser@ncqa.org.

Sincerely,

Margaret E. O’Kane
President

Subscribe to NCQA Emails:
Your Email	Subscribe