NCQA has not made a decision about incorporating the PHQ standards into health plan accreditation. Should NCQA decide to do so, it will put such a proposal out for Public Comment.
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11.17.2008 PHQ and HP Accreditation When will the PHQ standards be folded in to the health plan accreditation standards?
11.17.2008 Small physician sample size If only a small percentage of available physicians in any specialty within a market have sufficient NQF measures available, may there be an assumption of appropriate quality, thus allowing members access to higher benefits with a larger number of physicians?
11.17.2008 Relative Resource Use (RRU) Measures Are HEDIS RRU measures appropriate for PHQ 1 Element B?
11.17.2008 Productivity measures Are productivity measures within scope? For example, number of visits per half day: does NCQA classify this as a utilization measure or as something else?
11.17.2008 Certification time limits How long does certification last?
Certification in PHQ, PQ or HQ is valid for two years. Organizations must undergo a survey against the standards at least every two years to maintain their certification status. Provisional Certification is valid for 12 months; it is a temporary option and will not be offered after June 30, 2009.
11.17.2008 Physician requests For PHQ 1 Element G, could a collaborative manage the process?
Yes. PHQ requirements do not prohibit a collaborative from managing a request for corrections or changes made by physicians, but the organization remains accountable and responsible for responding to complaints from consumers and to requests for changes from physicians or hospitals based on actions taken by the organization.
11.17.2008 Pay for Performance Is consumer transparency required for certification? Our program is pay for performance targeted at physicians and hospitals only.
If the organization seeks certification, NCQA evaluates all measures on which it bases action against all elements. If the organization has a physician pay-for-performance program that meets the definition of taking action, then it must meet the elementsincluding all transparency requirements, including, but not limited to, requirements for making available to customers methodology and information about how the measures are used, providing opportunities for input, seeking feedback and having a process for complaints.
If the organizations pay-for-performance program was not designed to include public reporting of physicians measure results, then the organization is not required to make the individual measure results available to customers.
11.17.2008 Pay for Performance The draft program did not pertain to pay-for-performance programs, whose goal is QI at the practice, not public disclosure. Why was this added to "taking action?"
In the draft standards released for Public Comment in March 2008, NCQA included pay-for-performance but did not use that specific term; instead, we referred to payment strategies. Specifically, NCQA defined the Scope of Review for the majority of elements in PHQ 1 as: NCQA evaluates all measures the organization uses for measuring physician performance for the purpose of taking action.
In the Explanation, NCQA defined taking action as follows.
Publicly reporting physician performance on quality or cost or resource use
Using physician performance on quality or cost or resource use measures as a basis for network design (such as tiering), benefit design or payment strategies
NCQA defined payment strategies in Element M, Using Measure Results as follows.
The organization uses reimbursement to provide incentives for improvement among its physicians, practice sites or medical groups, or uses payment to reward performance.
In the final standards, NCQA used the term pay-for-performance and specifically narrowed the scope of programs included.
11.17.2008 Use of rental networks and hospital quality For PHQ 2, Element E, if we "rent" our national hospital network and do not contract directly, may we share hospital results with the entity we rent from, rather than the individual hospitals?
Each hospital must receive results. Either the organization must provide results to each hospital or it may have a written agreement with the national network stating that it will provide results to hospitals. If the national network provides results to each hospital, it must provide documentation (e.g., reports, materials) to the organization that it has met the requirements.
11.17.2008 Taking action on cost measures Is an organization prohibited from using cost efficiency if quality results are not available?
Yes. The organization may not take action based on cost, resource use or utilization results alone. This is a must pass requirement for certification and is consistent with the Consumer-Purchaser Disclosure Project Patient Charter.
The organization is required to consider quality in conjunction with cost, resource use or utilization when it takes action. To the extent that the organization develops and presents a composite score or rating using cost, resource use or utilization and quality measures, it must disclose the specific measures for each category and their relative weight when it determines the composite or rating.
11.17.2008 Differences between health plan (MCO/PPO) and PHQ standards We went through MCO accreditation in 2007. PHQ standards were required in our standards. How is this different? How is this the same?
11.17.2008 PHQ and Physician Practice Connection Recognition Do you have a crosswalk for PHQ as it relates to Physician Practice Connection (PPC) Recognitionstandard 8 in particular?
No. The PHQ standards evaluate organizations that measure physician performance; PPC recognizes physician practices that use systematic processes and information technology to enhance quality of patient care. The two programs serve different purposes. In particular, PPC 8: Performance Reporting and Improvement focuses on the practices internal measurement and quality improvement process. It does not address the methodology required in PHQ, but focuses on the QI process.