Friday, February 22, 2019

Very Brief Blog: Open for Public Comment, NCQA National Quality Measures

The National Committee for Quality Assurance (NCQA) maintains sets of measures that apply to health plans (HEDIS) and well as other organizations (e.g. Patient Centered Medical Homes.)  As a standards body, NCQA is separate from CMS, which has its own rosters of measures for ACOs, Medicare Advantage plans, etc.

Currently, NCQA is accepting public comment on its measures for Patient Centered Medical Homes (PCMH) through March 4, and on Health Plan Accreditation through March 11.
  • See the NCQA home page here.
  • See the summary of proposed HEDIS changes here. (For instructions, here.)
  • See the web page about each measure vetted for a proposed change, here.
Examples of HEDIS changes include dropping a measure that checks whether arthritis patients are prescribed disease-modifying drugs (DMARDs; rationale, a fair percentage of patients don't need them but they're hard to identify in the measure).   See a 6 page PDF here.

Another measure up for deletion is related to osteoporosis screening, because of "concerns about the validity of capturing the specific evidence-based tests recommended for osteoporosis screening using a survey question."  See a 12 page PDF here.

Among new measures, one is proposed for pharmacotherapy of opioid use disorder (here).
  • This is a typical example of the measure progression.  
    • It's a measure developed by RAND (presumably somebody funded RAND to do so....)
    • It's stewarded by USC.  That means they shepard it through the NQF process.
    • It's approved and archived in a library at NQF as NQF Measure #3175.  Here
  • The measure looks to, "the percentage of adults [diagnosed with OUD] who receive OUD pharmacotherapy and adhere to continuous treatment for at least 180 days, allowing for 7 treatment gap days." 

Digital Measure Strategy

NCQA also has an open docket, based on a 32 page white paper, on how it should approach Digital Health Measures, here.


NCQA also has a 35-page white paper on changes to its range of antibiotics measures, here.

Measure Process Alphabet Soup

Don't confuse NCQA with NQF, the National Qualify Forum, which holds libraries of of hundreds of vetted measures which specific bodies like CMS can bring their shopping cart to.  NQF here

CMS also maintains a complex Measures Management System (MMS) which keeps most aspects of measures development and measures proposal separate from the inpatient and outpatient rulemaking process itself.  (Primarily, just the final adoption of measures goes through notice and comment annual rulemaking).  See the MMS home website at CMS here

  • For example, via MMS, stakeholders can pick a measure already vetted and  archived by NQF in its measures library, and propose it to CMS as a future CMS measure.  
  • Then CMS can cherry-pick from these public MMS proposals to bring a possible measure or two into the spotlight of annual public rulemaking.
  • The measures then support VBP - Value Based Purchasing by CMS, such as bonuses and debits tied to measure performance.
The "Slow as Molasses" Measure (SaM)

Measures work on slow timelines, for example, NCQA/HEDIS is taking comments now on changes in measures proposed for 2021.  CMS also takes comment on measures it plans to implement 2-3 years in the future, in most cases.  And these processes all follow the year-plus process for NQF adoption of a measure after submission, as it moves through committees and comment cycles.