March 1, 2019
March 4, 2019
Consuela Benjamin,
Regulations Development Coordinator
Office of Regulation Policy & Management
Office of the Secretary, Department of Veterans Affairs
Attention: RIN 2900–AQ47
Dear Ms. Benjamin,
Thank you for the opportunity to comment on the proposed rule for VA MISSION Act provisions allowing veterans access to non-VA urgent care. The National Committee for Quality Assurance (NCQA) believes the rule should address quality, as well as access, particularly on well non-VA sites coordinate with other clinicians and facilities that veterans use.
We therefore urge you to include in contracts for non-VA urgent care providers a requirement to have earned NCQA Patient-Centered Connected Care Recognition. We specifically designed this program to help ensure that urgent, retail and other clinics connect and coordinate with their patients’ primary care providers. The program features these principles:
- Connect with primary care. The site connects with and shares information with patients’ primary care providers and helps them find a primary care provider if they need one.
- Identify patient needs. The site directs patients to appropriate providers, when necessary.
- Provide patient care and support. The site uses evidence-based decision support in care delivery, collaborates with patients to make care decisions and delivers culturally and linguistically appropriate services.
- Expand system capabilities. The site uses certified electronic health record technology to collect data, execute specific tasks and promote communication across providers and settings.
- Measure and improve performance. The provider systematically monitors performance and carries out activities to improve clinical outcomes and patient experience.
Patient-Centered Connected Care Recognition creates a roadmap for how urgent care and retail clinics can fit into the medical neighborhood of Patient-Centered Medical Homes (PCMH) and Patient-Centered Specialty Practices (PCSP). PCMH and PCSP standards closely align with MISSION Act nonurgent care quality standards, allowing the VA to avoid “re-creating the wheel” by requiring other non-VA providers to meet these ready-made standards.
We would be happy to share the full standards for each of these programs at your request.
Thank you again for the opportunity to comment on the draft. If you have any questions, please contact Paul Cotton, NCQA Director of Federal Affairs, at (202) 955-5162 or at cotton@ncqa.org.
Sincerely,
Margaret E. O’Kane
President