September 9, 2024
Chiquita Brooks-LaSure, Administrator
Centers for Medicare & Medicaid Services
Department of Health & Human Services
Hubert H. Humphrey Building
200 Independence Ave. SW
Washington, DC 20201
Attention: CMS-1807-P
Dear Administrator Brooks-LaSure:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on the CMS CY 2025 Physician Fee Schedule proposed rule.
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 to an equitable, digitally enabled 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 is pleased to provide comments in the following areas:
- Enhancing Access to Quality Care. NCQA applauds CMS for its proposals to enhance coverage for virtual primary and behavioral care services and define the role of community clinics and workers.
- Strengthening Care Coordination Across Settings. NCQA supports CMS in proposing value-based care arrangements to drive equitable, high-quality health care.
- Improving Quality Measurement for Better Outcomes. NCQA urges CMS to adopt digital quality measures (dQMs) in the Quality Payment Program and to align with the Universal Foundation.
Enhancing Access to Quality Care
NCQA applauds CMS’s sustained efforts to increase beneficiary access to equitable services, such as extending telehealth flexibilities awarded during the COVID-19 public health emergency and using telehealth to increase access to behavioral health and substance use disorder (SUD) services.
NCQA supports extending two-way, real-time, audio-only communication technology for beneficiaries and permitting auxiliary professionals to provide direct supervision through real-time audio and visual telehealth services. But while we support this expanded access, we believe standardization is needed in this area.
In 2024, NCQA released our Virtual Primary Care and Urgent Care Accreditation program to promote and facilitate virtual care delivery capabilities. This program aligns with CMS’s efforts to advance virtual care delivery as it continues to evolve. In addition, NCQA supports CMS’s proposed payment for digital behavioral health treatment devices. Increasing access to necessary services and improving the quality of behavioral health care are at the center of NCQA’s work and we welcome the opportunity to support CMS in standardizing virtual primary and behavioral health care.
NCQA is encouraged by CMS’s interest in defining the services Certified Community Behavioral Health Clinics (CCBHC) provide, and commends CMS’s collaboration with SAMHSA to expand these clinics. CCBHCs are integral to providing crisis stabilization services and behavioral health services to any person in need. In response to the expansion and interest in the services CCBHC’s provide, NCQA launched its CCBHC Accreditation program, which aligns with SAMHSA requirements and equips CCBHCs to successfully deliver behavioral health services, including intensive outpatient program (IOP) services. This program can improve CCBHCs’ quality infrastructure and support greater access to behavioral care through required reporting on crisis plan development and management, SUD treatment delivery and interdisciplinary care coordination. We encourage CMS to continue expanding access to behavioral health services, and we believe NCQA’s CCBHC Accreditation can be leveraged to meet the continuum of behavioral health services, including IOP, and ensure high-quality and streamlined care delivery.
We commend CMS for advancing a more community-based, person-centered Medicare program by introducing new codes for Community Health Integration (CHI) services that Community Health Workers (CHW) can provide. We also appreciate CMS’s request for input on auxiliary personnel and training. CMS can promote accreditation standards by clarifying that they meet training requirements for using CHI codes. This year, for example, TennCare (Tennessee Medicaid) implemented CHW accreditation through collaboration with the Tennessee Community Health Worker Association and NCQA. We believe CHW accreditation offers a robust, evidence-based approach to quality assurance and high-quality services for Medicare beneficiaries. Accreditation standards focus on organizations, rather than on individual CHWs, and encompass hiring practices, training and professional development, scope of practice, quality management and program evaluation. This rigorous approach ensures not only effective training, but also evidence-based service delivery and a supportive work environment.
Strengthening Care Coordination Across Settings
NCQA supports CMS’s efforts to improve value-based care arrangements, including the proposals for new HCPCS G-codes for advanced primary care management (APCM) and inclusion of Federally Qualified Health Centers (FQHC) and Rural Health Clinics (RHC) billing under general care management to provide equitable, streamlined and coordinated care to beneficiaries.
CMS selected nationally recognized accreditors, including NCQA, for the patient-centered medical home (PCMH) model to be used in the CMS MIPS/MVP program, and allows participating clinicians to earn full automatic credit in the MIPS Improvement Activities category. The PCMH model has historically advanced team-based, coordinated care for Medicare beneficiaries, and fulfills the intent of APCM. PCMH Recognition, in tandem with our Distinction in Behavioral Health Integration, helps practices incorporate behavioral health providers at the site of care, use independent providers and train care teams to address patients’ behavioral and substance use concerns. Both PCMH Recognition and Distinction in Behavioral Health Integration support clinicians in providing holistic care to beneficiaries and identifying and treating behavioral and physical health conditions. We encourage CMS to consider incorporating similar behavioral health integration practices into APCM, as PCMH practices that have earned Distinction can be rewarded in previous or newly proposed MVPs (e.g., Quality Care in Mental Health, Substance Use Disorder MVP). NCQA’s programs have provided primary care clinicians with the tools for population based, longitudinal and integrated care management, and can further bolster the success of APCM.
NCQA supports sunsetting MIPs to MVPs by 2029. We are encouraged by the proposed MVPs, as NCQA believes access to specialized services is a part of quality care. In our Patient-Centered Specialty Practice (PCSP) program, we recognize specialty clinicians who excel at care coordination and information exchange. We encourage CMS to align MVP measures with the Universal Foundation, where possible. We look forward to continuing our collaboration with CMS to reach our shared goals of burden reduction, health equity, care coordination and transitioning to digital quality reporting through the Universal Foundation.
With regard to Advanced Primary Care Hybrid Payment RFI metrics, NCQA’s Health Equity Accreditation provides a roadmap to health equity initiatives that can hold organizations and providers accountable for addressing beneficiaries’ social needs through evidence-based standards and reliable measures. NCQA is leading the way on stratified reporting of HEDIS measures to address health disparities and achieve equitable health care and outcomes. Through this Accreditation, beneficiaries can be assured that their providers deliver services with health equity in mind. NCQA anticipates working with CMS to promote evidence-based health equity practices as they are integrated into CMS’s payment models.
NCQA applauds CMS initiatives focused on RHCs and FQHCs using general care management, which creates separate codes for care coordination services and highlights their efforts to ensure that beneficiaries access necessary services through advanced care coordination. We support CMS allowing FQHC’s and RHCs to bill for services, such as community health integration and principal illness navigation, as it will foster health equity in the communities the FQHCs and RHCs serve. The general care management services coding proposals will expand resources for FQHCs and RHCs to deliver team-based, whole-person, coordinated care. Partnership between NCQA and CMS can support FQHCs in delivering equitable, high-quality reporting of primary care management.
NCQA supports CMS’s proposals to enhance the patient voice by establishing guiding principles for patient-reported outcome measures (PROM) and patient-reported outcome performance measures (PRO-PM). We are encouraged by the heightened interest in transitioning these measures to digital and leveraging them to improve health care quality. NCQA has found—through our own person-centered outcome (PCO) measures—that beneficiaries and physicians benefit from setting quality goals when a PCO approach is established. NCQA welcomes the opportunity to work with CMS to provide Medicare beneficiaries with valid and reliable PCO measures, and to make PROMs interoperable.
Improving Quality Measurement for Better Outcomes
NCQA supports CMS’s goal of transforming health care through data-driven, digitally enabled quality measures by 2030. We commend the proposals for the Quality Payment Program (QPP), including the Alternative Payment Performance (APP) Plus measure set and the introduction of new MIPS Value Pathways (MVP).
We support CMS’s proposal to align the APP Plus measure set with the Universal Foundation, and we believe a phased implementation of these measures will allow physicians to successfully report them. Although we encourage increased use of dQMs, like eCQMs, NCQA believes that required eCQMs should be released at least one year before their effective date so ACOs can plan for the technical builds currently needed with eCQM reporting. However, in the long run, we believe it’s in the best interest of CMS program participants if we begin to incentivize FHIR dQM reporting, over eCQMs.
NCQA welcomes the opportunity to explore solutions to advance digital data collection and reporting across CMS programs. Earlier this year we launched the NCQA Bulk FHIR Quality Coalition, an NCQA/public-private sector collaboration focused on the business use case of leveraging regulated FHIR data (including Bulk FHIR clinical data) for NCQA’s HEDIS measures. Phase 1 of the coalition involves payer-provider or ACO cohorts to create pipelines from clinical data (USCDI v1 data elements in US Core FHIR standard) and claims data (CARIN Blue Button FHIR standard), which are tested and validated against specific HEDIS FHIR Implementation Guides from NCQA. This collaboration will foster advancements to digital data collection and reporting against industry standards.
Additionally, in July, we launched our Digital Quality Hub, a resource all stakeholders can use in their digital transformation.
Thank you for the opportunity to comment. We remain committed to working with CMS 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
National Committee for Quality Assurance