October 28, 2022
The Honorable Ami Bera, MD
United States House of Representatives
172 Cannon House Office Building
Washington, DC 20515
RE: Medicare Access and CHIP Reauthorization Act Request for Information
Dear Congressman Bucshon and Congressman Bera:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on congressional actions to stabilize the Medicare payment system.
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 digital quality measurement. Leveraging our strengths as a trusted third party, we are committed to helping organizations navigate the challenges associated with burden reduction and moving toward a high-quality and equitable health care system. Our mission to improve the quality of health for all Americans, with an intentional focus on health equity and support for meaningful value-based payment models, propels our daily work.
NCQA is pleased to provide responses to the questions outlined in the request for information.
Benefits of the Medicare Access and CHIP Reauthorization Act (MACRA) for Clinicians
MACRA rates clinicians based on quality metrics, including many of NCQA’s HEDIS® measures, and directly rewards clinicians who earn NCQA Patient-Centered Medical Home (PCMH) Recognition. The PCMH model provides significant benefits for clinicians, including the potential to earn higher reimbursement and succeed in MACRA. Becoming an NCQA Recognized PCMH directly increases clinicians’ payments through the Merit-Based Incentive Payment System (MIPS). Clinicians in these PCMHs automatically get full credit in the MIPS Clinical Practice Improvement Activities category and will likely do well in other MIPS categories.
NCQA’s PCMH Recognition program provides a foundational model for health care organizations to transform primary care and is the most widely adopted medical home model for primary care in the country. It works to improve patient experience, staff satisfaction and health care efficiency—all while reducing costs. Over 100 payers and organizations offer enhanced reimbursement for PCMH Recognized clinicians, approximately 13,000 practices (with 67,000 clinicians) are recognized by NCQA, and the Centers for Medicare & Medicaid Services (CMS) acknowledges NCQA’s PCMH program as a way for clinicians to receive MACRA credit.
Opportunities to Strengthen MACRA
Although momentum for MACRA has slowed, there is an imperative for Congress to reward clinicians for taking steps to strengthen our nation’s primary care system and for prioritizing behavioral health. PCMH Recognized practices that excel in behavioral healthcare are eligible for NCQA’s Distinction in Behavioral Health Integration. Providing incentives for clinicians who participate in this program would not only increase MACRA’s effectiveness, but would also support behavioral health workforce improvement, an issue prioritized in the Senate Finance Committee’s mental health legislation. Most important, this incentive would support more practices in providing comprehensive care that acknowledges patients’ behavioral health needs. NCQA recommends Congress build on the existing PCMH credit in MIPS and expand additional credit to clinicians who achieve PCMH behavioral health integration.
Recommendations to Increase Provider Participation in Value-Based Payment Models
A primary reason for providers’ lack of participation in value-based payment models is the inability to show meaningful difference in quality outcomes and be rewarded for providing higher-quality care. For more meaningful value-based payment models, Congress should consider accelerating the move to digital quality measurement, to increase the quality of care and patient outcomes. Moving to a digital quality measurement system will dramatically boost the accuracy and effectiveness of the value-based payment model while reducing burden, enabling “smarter” measurement and generating significant administrative savings. The process of collecting data for use in performance and payment should be built into clinical workflows and provide both decision support and ongoing performance feedback.
To support the move to an all-digital quality measurement system, NCQA launched our inaugural Digital Quality Solutions Pilot in coordination with six trailblazing health plans, delivery systems and health IT firms. These organizations will provide vital feedback on the usefulness, feasibility and value of NCQA software and next-generation measure prototypes intended to align quality measurement across health care.
NCQA recommends Congress encourage CMS to provide financial incentives to clinicians for reporting digital quality measures. Requiring CMS to establish a quality bonus incentive in CMS programs would accelerate the adoption of digital quality measures in publicly funded health care programs and reward clinicians and providers for implementing systems that move away from paper-based reporting.
Thank you again for the opportunity to comment. We welcome the chance to discuss our experience and findings, and we remain committed to building a better quality, sustainable and responsible American health care system. If you have any questions, please contact Eric Musser, NCQA Assistant Vice President of Federal Affairs, at (202) 955-3590 or at musser@ncqa.org, or Olivia Umoren, NCQA Federal Affairs Manager, at (202) 827-9450 or at oumoren@ncqa.org.
Sincerely,
Margaret E. O’Kane
President
HEDIS® is a registered trademark of the National Committee for Quality Assurance (NCQA).