August 15, 2022
Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
PO Box 8013
Baltimore, MD 21244-8013
Attention: CMS-1776-P
Dear Administrator Brooks-LaSure:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to comment on the CY 2023 Home Health Prospective Payment System 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 health equity measurement. Leveraging our strengths as a trusted third party, we are committed to helping organizations navigate the challenges associated with addressing population health needs. Our mission to improve the quality of health for all Americans, with an intentional focus on health equity, propels our daily work.
NCQA is pleased to provide the following comments on the proposals and considerations outlined in the proposed rule.
Health Equity in the Home Health Quality Ratings Program—Request for Information
We commend CMS’s commitment to closing the equity gap in CMS quality programs, and we welcome the opportunity to work with CMS to adjust and align quality measures across those programs. We agree with other commenters on the CY 2022 HH PPS final rule (86 FR 62240), that relevant data collection and stratification are important to address equity gaps. We are committed to stratifying our HEDIS measure set, and we encourage CMS and other federal stakeholders to consider policy levers to increase collection of race, ethnicity and other demographic data. We recently published relevant recommendations with Grantmakers in Health (Federal Action Is Needed to Improve Race and Ethnicity Data in Health Programs).
NCQA has also developed a measure, Social Need Screening and Intervention, that assesses screening for unmet food, housing and transportation needs, and referral to intervention after a positive screen. This measure is specified for electronic reporting through Electronic Clinical Data System (ECDS) reporting, aligns with the Gravity Project’s standards and will be subject to the traditional HEDIS audit, to ensure valid results. Although this measure is currently specified at the health-plan level, we welcome the opportunity to work with CMS to ensure that measures of social needs across the delivery system are reliable, valid and ease the burden of collection.
Adoption of a structural composite measure for the Home Health Quality Ratings Program
NCQA shares CMS’s commitment to health equity, and we encourage the use of standards and measures to promote transparency and accountability for equitable health outcomes. We support the development and use of structural measures like the one proposed to address access and quality of home health care for underserved populations.
Existing NCQA programs address domains and elements of the structural composite measure described in the proposed rule. Our Health Equity Accreditation and Health Equity Accreditation Plus standards provide organizations with a structural framework, through process-based standards, to address and sustain health equity as an organizational priority. As care delivery providers, Home Health Agencies are eligible to earn both Accreditations.
As an example of the programs’ focus, Health Equity Accreditation’s “Organizational Readiness” standard requires organizations to build a diverse staff and to have recruiting and hiring processes that support diversity in the workforce. This includes identifying and acting on at least one opportunity to improve diversity, equity, inclusion or cultural humility for staff, leadership committees and governance bodies. The standard also requires organizations to provide at least one annual training to all employees on culturally and linguistically appropriate practices for reducing bias or promoting inclusion. The “Culturally and Linguistically Appropriate Services Programs” standard requires organizations to demonstrate health equity as an organizational priority by developing a program to improve the cultural and linguistic appropriateness of services offered and to reduce health disparities. Organizations are required to create measurable goals, establish a work plan that is monitored against goals and receive input and approval from a governing body.
Thank you again for the occasion to comment. We welcome the opportunity to discuss our experience and to collaborate with CMS, and we remain committed to improving health outcomes and building a more equitable health care system for all Americans. If you have any questions, please contact Olivia Umoren, NCQA Federal Affairs Manager, at (202) 827-9450 or at oumoren@ncqa.org.
Sincerely,
Frank Micciche
Vice President, Public Policy and External Relations