October 4, 2024
Micky Tripathi, PhD, MPP
Assistant Secretary and National Coordinator
Assistant Secretary for Technology Policy and
Office of the National Coordinator for Health Information Technology
U.S. Department of Health and Human Services
330 C Street SW
Washington, DC 20201
Attention: RIN 0955-AA06
Dear Dr. Tripathi:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on the ASTP/ONC Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability Proposed Rule (HTI-2).
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 their journey toward an equitable, digitally enabled health care system.
We are encouraged by ASTP’s HTI-2 update to align with the CMS Interoperability and Prior Authorization final rule. This alignment will help provide a foundation for nationwide interoperable health data exchange. We agree with the ASTP proposal to require USCDI v4 in the ONC Certification, and we encourage requiring USCDI+ Quality data elements in the certification. NCQA leverages USCDI/USCDI+ datasets in our HEDIS digital quality measures and implementation guides; we have digitized all 80 HEDIS measures using USCDI. But we believe updates are needed to ensure USCDI and TEFCA can support quality reporting.
As we responded in ASTP’s USCDI v5 request for comment, NCQA recommends adding Carin Blue Button Common Payer Consumer Data Set (CPCDS) elements to USCDI to support exchange of adjudicated claims information (without financial information). This will help USCDI further align with the CMS Prior Authorization and Interoperability rule and the Provider Access API, and allow EHRs to accept, store and use Carin BB CPCDS elements. Adding CPCDS elements to USCDI will align requirements across payers and health IT and will improve data-sharing abilities across health plans and providers.
We are encouraged that USCDI v4 will include SDOH assessment and intervention data elements, and we request that ASTP requires that EHRs map SDOH screening tools to the LOINC codes necessary to exchange data interoperability as a baseline feature of a certified EHR. Providers have noted EHR vendors’ exorbitant charges to access features that provide mapping. Interoperable information exchange is crucial to advancing health equity, addressing disparities and measuring the health care system’s collective progress in these areas. Without it, data exchange will not fully support the needs of clinicians, delivery systems, community organizations providing services and health plans that support payment for services.
We are encouraged by the collaboration with CDC to advance public health data exchange and the CDC’s Data Modernization Initiative. There are many commonalities between current/future data needed for public health and health care quality reporting. But we note that the existing CDC Race & Ethnicity Code Set (CDCREC) does not align with the updated 2024 OMB race and ethnicity categories. We encourage ASTP to partner with CDC to ensure an updated CDCREC is implemented to support adoption of revised OMB standards, as ASTP has done with USCDI.
NCQA visited with CDC leadership to discuss opportunities to align national measurement frameworks with interoperability standards. With over 226 million Americans enrolled health plans using NCQA HEDIS quality measures, the promotion of transparency, accountability is an important lever public health professionals can use to achieve national public health objectives and equitable health care outcomes. We fully support the proposals outlined in HTI-2 to advance public health data sharing.
We commend ASTP commitment and collaboration with CMS to help evolve the interoperability landscape. The upcoming mandates for API adoption in CMS’s program, and now the HTI-2 proposals to ensure alignment, are a step toward advancing America’s interoperability goals, particularly for health care operations and quality measurement. NCQA anticipates partnering with ASTP and the interoperability community to advance the HEDIS Level 2 use case for the Healthcare Operations SOP, which designated Qualified HINs are required to support in 2026. We believe this is an appropriate step and would like to work with ASTP and The Sequoia Project to help advance the HEDIS SOP. While this first step does not yet address the data quality or Bulk FHIR exchange issues NCQA is working on, we appreciate ASTP’s participation in NCQA’s Bulk FHIR Quality Coalition. We look forward to sharing what we’ve learned with the health care community, through our recently launched online Digital Quality Hub.
Thank you for the opportunity to comment. We are committed to working with ATSP to build a more equitable, sustainable, responsible American health care system. We welcome a discussion on our experience and our recommendations to continue to strengthen ATSP’s proposals for standardizing the exchange and use of electronic health information. 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
National Committee for Quality Assurance