October 15, 2023
The Honorable Michael Burgess, Chair
The Honorable A. Drew Ferguson, Member
The Honorable Lloyd Smucker, Member
The Honorable Earl L. “Buddy” Carter, Member
The Honorable Blake Moore, Member
The Honorable Rudy Yakym, Member
United States House of Representatives
Committee on the Budget
Health Care Task Force
204 Cannon House Office Building
Washington, DC 20515
Dear Representatives,
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on the House Budget Committee Health Care Task Force Request for Information (RFI) to support decreasing health care costs.
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 convener of health care stakeholders, we are committed to helping organizations navigate the challenges associated with improving the health care system. Our mission to improve the quality of health for all Americans, with a focus on support for meaningful, value-based approaches to health care delivery and payment, propels our daily work.
NCQA believes that reducing health care costs while improving patient outcomes requires innovation in both the delivery of care and payment approaches.
Examples of evidence-based, cost-effective preventive health measures or interventions that can reduce long term health costs
We applaud Congress for continuously demonstrating the importance of value-based, accountable care through amendments and enhancements to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). In recent congressional hearings, members highlighted the need to move providers toward value-based care while decreasing the associated reporting burden. The Digital Quality Measurement Strategic Roadmap, released by CMS, highlights that the transition to Digital Quality Measures (dQMs) will support these goals. We encourage Congress to support health care organizations in transitioning to dQMs by 2030.
dQMs are designed to closely align with interoperability and data exchange standards, making them easier to deploy and enabling knowledge sharing across the continuum of care. Unlike other electronic measures, dQMs aggregate health data across multiple sources to provide a more complete picture of a patient’s care. dQMs use Fast Healthcare Interoperability Resources (FHIR) standards for better exchange of health care and quality information. This interoperability, facilitated by recent regulations and proposed rules by the Office of the National Coordinator for Health IT, can support transparency for consumers while saving health care systems time and money: A recent JAMA article suggested that transitioning to dQMs could produce significant cost savings compared to the status quo, in which one health system reported spending more than $5.6 million per year to fulfill quality reporting requirements.
CMS has a number of proposals to move health care organizations toward digital quality measures. We are encouraged by these proposals, and recognize the benefits, but they do not move the entire health care system uniformly. We encourage Congress to invest in the infrastructure needed to fully implement dQMs across CMS programs. Congressional action will allow the entire health care system to move to this cost-saving reporting method, decrease long-term health care costs and support providers in moving to value-based care.
Providers in the Merit-Based Incentive Payment System (MIPS) will benefit from all dQM reporting. The design of MIPS today limits the ability to compare the quality of participating providers, and may disadvantage smaller provider groups, particularly in rural areas. These and other providers are left out of MIPS because measures do not meet the needs of their populations, which are among the most vulnerable. dQMs can remedy many of MIPS’ shortcomings by improving available measures and expanding providers opportunities to demonstrate meaningful value-based care.
Unmet social needs are associated with delays in preventive care. They also are associated with utilization of costly acute care services. We encourage Congress to seek outcome data from CMS and health plans on interventions to address social needs. In February, the standard-setting bodies of the Sync for Social Needs Coalition (NCQA, The Joint Commission, the National Quality Forum) released a Joint Statement on Digital Health Data Exchange of Social Determinants of Health Assessments. When social needs are addressed, patients have improved health outcomes, which can lower long-term costs. While this work is ongoing, this information should be collected in a standardized way. FHIR health data standards enable exchange of data among providers, reduce redundant data collection and ensure a closed loop in provision of services and support to patients.
Efforts to promote and incorporate innovation into programs like Medicare to reduce health care spending and improve patient outcomes
As more Medicare beneficiaries are electing Medicare Advantage, standardization of health data can enable effective monitoring of cost-reducing innovations on patient outcomes. We urge Congress to require comprehensive accreditation of MA plans that combines clinical performance and consumer experience. Accreditation will clarify the value of MA plans and their benefits to patients for Congress, CMS and the public. NCQA is one of a number of national accreditation bodies that monitor health plan performance and support improving health outcomes.
NCQA Health Plan Accreditation supports plans as they perform gap analysis and align improvement activities with areas such as network adequacy. Accreditation also leverages the Healthcare Effectiveness Data and Information Set (HEDIS), one of health care’s most widely used performance improvement tools, to compare outcomes. More than 200 million patients are enrolled in plans that report HEDIS results. CMS could better monitor health plan performance through national Health Plan Accreditation and could more easily identify high-value care and innovation for incentives. This would build on existing CMS efforts to align reporting and decrease burden.
In March, CMS released the Universal Foundation design to create consistency across value-based payment programs, advance population health and support the transition to digital reporting. The Universal Foundation focuses the efforts of providers on key drivers of health disparities, allowing CMS and health care organizations to track progress uniformly. We encourage Congress to promote incorporation of the Universal Foundation measures into more value-based payment programs across CMS. By aligning the collective efforts of providers and payers, we can be better equipped to address the challenges facing patients, and ultimately decrease costs.
Thank you for the opportunity to comment. We remain committed to working with Congress and CMS to build a more equitable, sustainable and responsible American health care system. If you have any questions, please contact Michael J.E. Grier, Director of Federal Affairs, at (202) 810-3298 or at mgrier@ncqa.org.
Sincerely,
Margaret E. O’Kane
President