March 29, 2023
The Honorable Bernard Sanders, Chair
The Honorable Bill Cassidy, Ranking Member
The Honorable Robert P. Casey, Jr., Member
The Honorable Mitt Romney, Member
United States Senate
Committee on Health, Education, Labor and Pensions
428 Senate Dirksen Office Building
Washington, DC 20510-6300
Dear Senators:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to respond to the request for information on the Pandemic and All-Hazards Preparedness Act (PAHPA) reauthorization.
NCQA is a private, 501(c)(3) not-for-profit organization dedicated to improving health care quality through our Accreditation and measurement programs. We are a national leader in quality oversight, at the forefront of the movement to modernize the exchange of health information. Leveraging our strengths as a trusted third party, we work with federal agencies, states, practitioners and managed care organizations to drive alignment, improve quality and advance health outcomes across the country. With more than three decades of improving the quality of American health care, we offer the following recommendations to the Committee to strengthen the nation’s ability to prepare for and respond to future pandemics.
As the Committee deliberates on enhancements to the public health infrastructure for future pandemics, it will be essential to include the components of a fully interoperable health system. The nation needs an infrastructure that allows rapid dissemination of new knowledge based on trustworthy data. The COVID-19 pandemic highlighted our public health system’s inability to rapidly develop clinical guidelines, related decision supports and quality measures to assess their implementation.
For more than 30 years, quality measurement has driven remarkable improvements in health care—but the current quality measurement system, which collects data manually, is fragmented, labor-intensive, inconsistent and retrospective. Clinical quality measurement has provided an effective use case for efforts to improve the quality and accessibility of data produced by health care entities, like laboratories, but these efforts have not typically included the use of public health information. Digital quality measures (dQM) that use interoperability standards offer a unique opportunity to expand the use of high-quality, standardized information from across the clinical and public health data spectrums. These measures are a critical component of a fully interoperable learning heath system that generates accurate and reliable knowledge at a time when it is most valuable.
Improving the accuracy and availability of comprehensive health care information can result in better measures, better measurement systems and better response to future pandemics. It is important to recognize the role of ongoing efforts to incorporate public health information into clinical measurement systems (e.g., the CDC’s MedMorph project) that can not only support quality, but also support the nation’s ability to respond to public health emergencies.
Implementing technologies that move away from paper-based reporting can be resource intensive and time consuming. CMS has released a strategic roadmap calling for all-digital reporting in the next decade. The Committee has the opportunity to encourage HHS to accelerate the move to a fully digital public health reporting ecosystem, with dQMs as a core component. We urge Congress to consider including language in the PAHPA reauthorization that instructs CMS to incentivize dQM reporting in Quality Payment Programs; doing so would bolster the nation’s ability to quickly respond to emerging and ongoing threats to public health.
Thank you for the opportunity to comment. We remain committed to working with the Committee to build a more sustainable and responsible American health care system. 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