The National Committee for Quality Assurance (NCQA) released a report recommending the Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) push for the creation of a digital quality measure system that could eliminate much of the redundancy in quality data reporting and improve the value of the data.1
The report also calls for HHS and CMS to take steps to improve health equity, which could be addressed in part by a better data reporting system. CMS is moving in that direction, and there are indications the agency is accelerating the effort, with bold goals and extensive plans for a new digital quality reporting system. The HHS Assistant Secretary for Planning and Evaluation has urged CMS to incorporate health equity data in its quality measurement and incentive programs. Health equity data is a factor included in value-based care models in some states.1
NCQA notes healthcare data and quality measures are fragmented across healthcare organizations and health plans, making it difficult to provide value-based care. A digital quality system would reduce the time and cost required for developing and implementing value-based care measures, according to the agency. NCQA also urged Medicare to strengthen value-based care plans as a way of improving health equity.
Need to Improve Quality Reporting
NCQA focuses on the quality assessment of health plans and relies on automated, validated data, says Frank Micciche, vice president of public policy and external relations with NCQA. All healthcare organizations and health plans should be able to rely on the same level of quality data.
“One of the things we’re recommending is that various CMS programs improve their data quality. Obviously, Medicare and Star Ratings is the top-notch program in terms of their quality ratings and the data they use,” Micciche says. “But there are plenty of CMS programs and value-based payment programs across the country, private and public, where the data are just whatever data you can get to them. It often is not validated and rarely audited.”
The federal government is making billions of dollars of payments based on “pretty shaky data,” Micciche says. NCQA is calling for validation and auditing to become standard parts of any public value-based program, and ideally for private programs, too.
“We would like to see the creation of an ecosystem that makes it easier and actually reduces the burden to feed data into this ecosystem. In the course of doing, you validate and audit data in a way that you can’t right now,” Micciche says. “That’s a big leap. There’s a long way to go before everyone can plug into a system like that, even if they’re relatively sophisticated with their data. We and the rest of the healthcare data community have to create that interface.”
CMS is most capable of facilitating progress in that direction, according to Micciche. CMS can incentivize the use of a digital ecosystem or even mandate it, which would be harder.
CMS Shoots for 2025
CMS announced during its 2021 Quality Conference in March that it was moving up its goal to report all quality measures digitally. Originally, the agency said it would be done by 2030; now, the date has changed to 2025. Micciche calls that a bold move and an ambitious goal.
“That fits very nicely with what we are trying to do. Whether folks can get there by then is a real question,” Micciche says. “Even those with EHRs [electronic health records] and more sophisticated data systems or quality measures still aren’t interconnected or interoperable. There’s a long way to go, but we believe a smoother, more coordinated ecosystem is going to bring us to a point where data are just flowing as opposed to being entered and re-entered.”
If data must be manually entered into the system, which Micciche says will be the case for many entities for some time, those data can be validated and redistributed to various other entities automatically.
“A current complaint from many health plans and other organizations is that they are reporting the same measure to five different entities or some version of the same information to five different entities,” Micciche says. “That is chaos. Not only does it take up a lot of time, but it creates a sense of confusion over what target you’re really aiming for with these data — the version you report to these guys, or the version you report to someone else.”
The NCQA report says the digital quality utility it envisions aligns closely with the “secure, data-driven ecosystem to accelerate research and innovation” contemplated in the 2020-2025 Federal Health IT Strategic Plan.1 NCQA’s plan would support CMS’ goal of requiring all quality measures to be reported digitally by 2030.
The authors cited the example of Electronic Clinical Data System (ECDS) measures, which are derived from digital resources such as EHRs, health information exchanges, and registries.
NCQA points out that the ECDS measures make it possible to measure individual member outcomes in addition to general population outcomes.1
Star Ratings Set the Standard
NCQA says the Medicare Advantage (MA) Star Ratings program is a good example of how financial incentives and quality measurement improve patient outcomes in a value-based care model.
“MA has seen a surge in enrollment, while also improving quality, containing costs and premiums, and enabling individuals to choose from an array of high-quality plans,” the report authors wrote.1
More than 80% of MA plans include complete or partially complete race and ethnicity data. On the other hand, most Medicaid and commercial plans do not routinely collect information on race or ethnicity, which makes it difficult for them to assess or address inequities.1
“Plans can serve as critical partners to effectively tackle the root causes of poor health and address disparities to improve the health of individuals and their communities,” the NCQA report says. “This is reflected in the continued investment and increase in supplemental benefits offered by MA plans to address social determinants of health.”1
If that interoperability is achieved, hospitals should be able to seamlessly exchange data not only with other hospitals but also with health plans, Micciche says.
“If we get this right, there is no reason it cannot apply to data between systems and hospitals, between hospitals and plans, between doctors and hospitals,” he says. “A rising tide lifts all boats and hospitals are certainly one of those boats. This will be a major improvement for hospitals because making data flow more interoperably will allow all sorts of new connections that currently are just impossible.”
CMS Making Right Moves
Micciche sees progress in working toward the goals of digital reporting of quality data and creating a more comprehensive system that facilitates the easy flow of information and reduces much of the redundancy and work burden of the current system. CMS’ adoption of the Fast Healthcare Interoperability Resources (FHIR) as the foundational standard to support data exchange via secure application programming interfaces (APIs) was a major step forward.2
“I think FHIR is becoming the coin of the realm. For those who are in a position to strive for this digital quality ecosystem in which we enter data once and it gets shared around, they at least now know that CMS, the big driver here, is saying you need to move to this FHIR API that will allow connection between all sorts and types of entities.”
CMS moving up its deadline for digital quality reporting also is progress, because nothing gets people moving like a hard deadline, according to Micciche.
“Moving it from 2030 to 2025 is a massive leap for a government to take. It’s two different administrations, but I don’t get the sense that this is a Biden administration decision so much as evidence that the career people at CMS believe it is doable by 2025,” Micciche says. “If it is more than two or three years out before people have to start buying new systems, they kick it down the road to the next strategic plan. CMS moving that deadline forward is going to cause a lot of movement toward this digital capability.”
Shift Needs Good Oversight
However, that movement has to be shepherded carefully, Micciche says. The adoption of EHRs is a good example of how a massive shift in technology was not shepherded well.
The government pushed for widespread adoption of EHRs with incentives and funding. Today, most any healthcare provider that wants an EHR owns one. But their contribution to improving data reporting and analysis is spotty, at best, Micciche argues.
“They meet some vague definition of interoperability, but they are not seamless. They do not communicate well. Even with a health system, they have a hard time communicating and sharing data,” he says. “This needs to be scale of commitment, as well as policy leadership and funding, but it needs to be done in a way that gets us to far more interoperability than we have now.”
The Office of the National Coordinator for Health Information Technology (ONC) will be a driving force in reaching this goal, with the new leadership setting fresh standards that will guide the industry to infrastructure improvements necessary to create the digital quality ecosystem. ONC also can encourage interoperability in ways that do not involve new standards or penalties.
Micciche was particularly encouraged by the release of the CMS Measures Management System Blueprint at the 2021 Quality Conference. The document outlines specific steps necessary to achieve interoperability.3
“The new director of ONC is indicating that he is very supportive of this goal. We are seeing strong signs that the government is activated on behalf of moving to this digital vision,” Micciche says. “This isn’t just words on paper. They’re making those plans and charting a course that makes it doable. It doesn’t mean we’ll get there by 2025, but we feel great about the direction this administration is taking.”
- National Committee for Quality Assurance. The Future of Healthcare Quality. Recommendations from NCQA to the Biden-Harris HHS Transition Team. December 2020.
- eCQI Resource Center. Fast Healthcare Interoperability Resources.
- Centers for Medicare & Medicaid Services. CMS Measures Management System Blueprint Version 16.0. September 2020.
- Frank Micciche, Vice President, Public Policy and External Relations, National Committee for Quality Assurance, Washington, DC. Email: firstname.lastname@example.org.