NCQA Comments on ONC’s Draft USCDI+ Behavioral Health Dataset

NCQA believes it is critical to keep all USCDI+ datasets consistent and coordinated with each other to ensure alignment of efforts and successful use of the datasets. NCQA makes recommendations for the USCDI+ BH data elements, level of specificity and integration of elements related to physical health.

May 11, 2024

Micky Tripathi, Ph.D., M.P.P
National Coordinator for Health Information Technology
U.S. Department of Health and Human Services
Re: Draft USCDI+ Behavioral Health Dataset

Dear Dr. Tripathi:

The National Committee for Quality Assurance (NCQA) thanks ONC for the opportunity to provide feedback on the draft USCDI+ Behavioral Health 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 their journey towards 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 intends to leverage the USCDI, USCDI+ Quality, USCDI+ Behavioral Health, and other USCDI+ datasets in our digital future. This is essential to NCQA’s work and we believe it is critical to keep all USCDI+ datasets consistent and coordinated with each other and with the USCDI, where appropriate, to ensure alignment of efforts and successful use of the datasets.

We look forward to supporting this important initiative and offer the below comments. 

  1. Data Element Completeness for Behavioral Healthcare: Does the USCDI+ BH dataset contain all core elements important for behavioral health services and outcomes? Are there any data elements that might not be clinically relevant to behavioral health and should be removed?
  1. Behavioral Health Status Screens Data Class: NCQA recommends adding these additional elements to the dataset:
    • Add data element specific to Depression Screen.  This will support the evaluation of an individual’s status and potential mental health diagnosis. Having a separate Depression Screen data element in addition to the existing Mental Health Status Screen will allow for the specificity necessary to support ongoing measurement-based care.
    • Add data element specific to Anxiety Screen. This will support identifying potential signs of mental health disorder and need for more comprehensive assessment specific to anxiety disorder diagnosis. Again, we recommend a specific Anxiety Screen element in addition to the existing Mental Health Status Screen. 
  2. Encounter Information Data Class: NCQA recommends adding the following additional element to the dataset:
    • Add a data element for Diagnosis Rank. Diagnosis rank is important encounter diagnosis information to support identification of primary diagnoses for ongoing care and for behavioral health quality measurement. NCQA utilizes diagnosis rank in quality measures to assess primary and secondary diagnoses and measure population eligibility for important behavioral health quality measures.
  3. High Risk Behavioral Health Indicators Data Class: NCQA recommends adding these additional elements to the dataset:
    • Add a data element for Instances of Self-Harm in the Last 30 Days. Although an existing data element assesses recent suicide attempts, it is also important to capture instances of self-harm without suicidal intent, given that non-suicidal self-injury is a risk factor for suicide and is associated with other adverse behavioral health outcomes (e.g., alcohol abuse, depression).
    • Add a data element for Number of Days Client Experienced Suicidal Ideation in the Past 30 Days. Suicidal ideation is a risk factor for suicide attempts and completions and is a potential indicator of the presence of mental health conditions or substance use disorders requiring further evaluation and treatment. A distinct element for suicidal ideation, in addition to the existing suicide attempts element included in the dataset, will support creation of a comprehensive USCDI+ Data Class.
  4. Medications Data Class: Complete medication information, including the data elements recommended below, is critical for appropriate and comprehensive care. NCQA recommends adding the following elements:
    • Add a data element for Date Medication Dispensed. This data element should be distinct from the existing USCDI+ Behavioral Health data elements for Date Medication Prescribed and Date Medication Administered. Specifically, NCQA utilizes dates of dispensing events in our behavioral health quality measures for measure component definitions.
    • Add a data element for Medication Days Supply. NCQA utilizes this element in our behavioral health quality measures.
  1. Level of Specificity: Are the data classes and data elements listed detailed enough to allow staff to collect data easily and accurately?
    1. Health Status Assessments Data Class: NCQA recommends modifications to the following data element to improve specificity and usability:
      • For the Substance Use data element, consider refining the definition to clearly outline use of different substances, including marijuana, cocaine, heroin, hallucinogens, inhalants, methamphetamine, prescription psychotherapeutics (e.g., pain relievers, stimulants, tranquilizers/sedatives), opioids, and central nervous system stimulants. Specificity of substance use supports appropriate care and allows for appropriate reporting for quality measurement and other uses.
    2. Behavioral Health Status Screens Data Class: NCQA recommends modifications to the following data element to improve specificity and usability:
      • Rename the Psychological Functioning Assessment data element to Cognitive Functioning Assessment. As the data element is defined as, “An evaluation of a client’s cognitive functioning,” renaming it to Cognitive Functioning Assessment will more accurately reflect the data element’s specific focus on cognitive functioning as opposed to psychological functioning more broadly.
  2. Integration of elements related to physical health: The draft USCDI+ BH dataset is currently organized with two use cases to promote high-quality, integrated care: The Behavioral Health Overarching use case and the Behavioral Health Comprehensive Care use case. Would it be helpful to combine both use cases in the full USCDI+ BH list? What other behavioral health use cases should we consider?  How well do the data elements support the integration of physical and behavioral health care? Are there any other data elements that would be useful for supporting and understanding physical and behavioral health care integration? 

    NCQA considers the integration of physical and behavioral healthcare to be a key priority area for healthcare quality improvement and believes it is critical to include data elements within the USCDI+ BH dataset that support high-quality integrated care. Many practices are early in implementing or have not yet embraced integrated care models. We recommend that if the use cases remain distinct within the USCDI+ dataset, ONC take steps to ensure this separation does not hinder the goal of promoting seamless integration of physical and behavioral healthcare.  
  3. General Recommendations

    NCQA seeks clarification and guidance on if and how the USCDI+ BH dataset will intersect with ONC regulation. We recommend ONC define a path for USCDI+ BH and other USCDI+ data elements to transition to USCDI, and clarify if there will be other regulation associated with the USCDI+ BH dataset to support nationwide exchange. This pathway will support unlocking true interoperability of domain-specific data.

NCQA thanks ONC for the opportunity to comment on the draft USCDI+ Behavioral Health dataset. We welcome a discussion on our experience and recommendations and look forward to continued collaboration on this important effort. 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

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