July 22, 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+ Maternal Health Dataset
Dear Dr. Tripathi:
The National Committee for Quality Assurance (NCQA) thanks ONC for the opportunity to provide feedback on the draft USCDI+ Maternal 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 and 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.
NCQA is generally supportive of the included elements in the draft dataset to support maternal health services and outcomes. NCQA and The Praxis Project (formerly RH Impact) have partnered on the Birth Equity Accountability through Measurement (BEAM) initiative. Our goal is to develop, validate, and implement an actionable set of quality measures that align the health care system toward birth equity over the next five years. Many of the data elements included in the USCDI+ dataset will support the high priority measurement concepts identified to date via our work. We applaud the inclusion of elements related to SDOH, lactation, adverse events, health status assessments, gestational age, care team members that capture doulas and birth workers, and severe morbidity diagnoses. We look forward to supporting this important USCDI+ initiative and offer the below comments to improve the completeness and specificity of the dataset.
- Medications Data Class: NCQA recommends adding additional elements to the dataset to ensure complete medication information is available. NCQA uses medication information in quality measures to assess the quality of maternal health care:
- Medication Dispensed (as included in the Behavioral Health and Public Health Domains). This element is important for understanding medications used in prenatal and postpartum care.
- Medication Administration (as included in the Quality Domain). Medications administered during a pregnancy or labor/delivery encounter are critical information for maternal health.
- Behavioral Health Data Class: NCQA recommends adding the following elements to the data class:
- Instances of Self-Harm in the Last 30 Days. It is important to capture instances of self-harm 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). Capturing instances of acute self-harm during the perinatal period (and not solely a mental health diagnosis) is crucial to identifying pathways for early prevention. NCQA also recommended this element be added to the USCDI+ Behavioral Health dataset.
- Instances of Suicidal Ideation in the Last 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. An estimated 10% of deaths during the pregnancy period and up to 1-year postpartum can be attributed to suicide.
- Patient Demographics Data Class: NCQA recommends refining the following elements in the data class:
- Race and Ethnicity data elements. NCQA recommends ONC update the Race and Ethnicity data elements to align with the OMB revisions to the Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (SPD 15), published on March 29, 2024; it replaces and supersedes OMB’s 1997 Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity. First, in alignment with the revised SPD 15, we recommend ONC combine the individual race and ethnicity elements to create one data element: Race and/or Ethnicity. Second, we recommend ONC update the terminology requirements for the Race and/or Ethnicity data element to reference the March 2024 revised SPD 15. We also encourage ONC to partner with CDC to ensure the CDC Race and Ethnicity Code Set is updated and appropriately included within the terminology requirements.ONC plays a pivotal role in ensuring federal entities, NCQA and other organizations are positioned to align with these revised OMB standards to support collection and exchange of more accurate and useful race and/or ethnicity data. Our ability to maintain alignment with OMB’s standards is directly facilitated by ONC’s promulgation of the standards into the USCDI and USCDI+ requirements, which subsequently will facilitate alignment across other standards, including FHIR.
- Other Future Considerations
- NCQA recommends future integration of data elements capturing psychological traumatic events experienced by birthing people in the prenatal, labor/delivery and postpartum phases. Concurrent to data elements identified for physical traumatic events, data elements capturing psychological impacts/diagnosis that can have co-occurring and long-term effects on the birthing person and child/family are important. NCQA has identified this as an important future quality measurement area for birth equity and looks forward to working with ONC to incorporate into USCDI+ as requirements are further defined with expert input.
NCQA thanks ONC for the opportunity to comment on the USCDI+ Maternal 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, Assistant Vice President of Federal Affairs, at (202) 955-3590 or at musser@ncqa.org.
Sincerely,
Margaret E. O’Kane
President