March 1, 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-2024-0006
Dear Administrator Brooks-LaSure:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on the Advance Notice of Methodological Changes for Calendar Year (CY) 2025 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies.
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 toward 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 the following comments on the proposals and considerations outlined in the Advance Notice.
Changes to Existing Star Ratings Measures for the 2025 Measurement Year and Beyond
NCQA supports CMS’s goal to align Medicare Advantage Star Rating measures with the Universal Foundation. The Universal Foundation is crucial to support of the industry’s move to digital quality measures (dQMs). We are proud that 70% of the measures in the Universal Foundation are HEDIS measures, and that all are dQMs. We are excited to see alignment between CMS’s efforts and our work to promote high-quality, equitable care by moving to next-generation digital measurement, and measuring what matters across the continuum of care.
Measure Updates
NCQA supports CMS’s consideration of including updates to Statin Therapy for Patients With Cardiovascular Disease and Diabetes Care—Eye Exam, and looks forward to finalizing the HEDIS updates in upcoming measurement years. Quality measurement for diabetes remains critically important, as one out of every three Medicare beneficiaries has diabetes. In March 2023, NCQA and the American Diabetes Association invited a panel of health care experts to a roundtable discussion on digital diabetes technologies (DDT). This resulted in a white paper highlighting new approaches to grouping DDTs, identifying a DDT framework and developing quality standards and measures. Developing DDT standards and measures promises to improve the quality of diabetes care, and bring more equitable care to millions of people with diabetes. The NCQA Diabetes Recognition Program provides clinicians with tools that support delivery of high-quality care to patients with diabetes. We launched a refreshed version of the program in September 2023 with a grant from the Helmsley Charitable Trust. The revamped program incorporates an enhanced platform, an updated set of measures that encompass kidney health and Annual Reporting to maintain Recognition.
NCQA also appreciates CMS’s attention to two cross-cutting updates to HEDIS measures: Identifying Chronic Conditions and Gender-Affirming Quality Measurement in HEDIS. NCQA is reevaluating how to identify people with chronic conditions across HEDIS measures, with the goal of updating the claims-based approach currently in use and introducing an alternative method that uses clinical data. We remain committed to revising measure specifications to avoid gendered language when describing eligible populations, and we are focused on inclusive and gender-affirming approaches that align with the intent of the measures and are supported by clinical evidence.
Display Measures
NCQA agrees with keeping the Follow-Up After Hospitalization for Mental Illness measure on the Star Ratings display page. Behavioral health measures are an important component of whole-person care; their inclusion in the Universal Foundation and in Medicare Advantage Star Ratings will incentivize focus on this critical area. NCQA recently published two resources on this topic: Behavioral Health Care Integration: Challenges and Opportunities for Quality Measurement and Improving Accountability for Behavioral Health Care Access. We look forward to working with CMS to advance behavioral health accountability in the Medicare program.
We also support adding the Adult Immunization Status measure to the 2026 display page. NCQA is currently seeking public comment (through March 13) on this measure, in addition to nine others. We look forward to feedback on our proposed measures, on updates to existing measures and on cross-cutting items.
NCQA also thanks CMS for adding the Social Need Screening and Intervention measure to the 2025 Star Ratings display page. This measure, introduced into the HEDIS performance measurement set in 2023, assesses members who were screened for unmet food, housing and transportation needs, and who received a corresponding intervention if they screened positive. We continue to explore adding utility insecurity screening and intervention rates to the measure for measurement year 2026. The screening rate would gauge the percentage of members screened for unmet utility needs; the intervention rate would measure the percentage of members who received appropriate intervention within 30 days of screening positive. These updates align with the Gravity Project and CMS’s Addressing Social Needs eCQM. We look forward to stakeholder feedback throughout the measure development process.
Potential New Measure Concepts and Methodological Enhancements for Future Years
NCQA applauds CMS’s efforts to adopt measures that leverage electronic clinal data. We appreciate CMS leveraging NCQA’s HEDIS Electronic Clinical Data Systems (HEDIS ECDS) reporting standard, which gives health plans a method for collecting and reporting structured electronic clinical data for HEDIS quality measurement and improvement from a variety of sources, not just from EMRs. We welcome the opportunity to work with CMS and its partners on the collection, validation and eventual transition of this reporting method to all-digital reporting.
We support CMS’s consideration of ECDS measure concepts under active development at NCQA. Tobacco Use Screening and Cessation Intervention and Lung Cancer Screening are being developed and tested together for use in all product lines. The tobacco use screening measure is based on the eCQM, Tobacco Use: Screening and Cessation Intervention (CMS 138). NCQA intends to align the two measures; any enhancements to the HEDIS measure will also be considered for the eCQM. We believe continued alignment of quality measurement across provider and payer programs will improve the quality of health care while reducing administrative burden.
Other ECDS measure concepts under development include Blood Pressure Control for Patients With Hypertension, Documented BI-RADS Assessment After Mammogram and Follow-Up After Abnormal Breast Cancer Assessment. We look forward to feedback on these potential new measures, and to eventually including them as display or Star Ratings measures.
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. We welcome a discussion on our experience and recommendations to continue to strengthen Medicare Advantage. 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