September 26, 2017 United States Huse f Representatives Cmmittee n Ways & Means 1102 Lngwrth Huse Office Building Washingtn D.C. 20515 WMPrviderFeedback@mail.huse.gv Dear Chairman Tiberi: Thank yu fr the pprtunity t ffer ur cmments n the Huse Ways & Means Health Subcmmittee s Prvider Statutry & Regulatry Relief Initiative. The Natinal Cmmittee fr Quality Assurance (NCQA) is striving t significantly reduce burden by develping a fully autmated system fr quality measure reprting. This will: Allw physicians and ther health prfessinals t fcus n patient care; Prvide ready access t much richer clinical data in electrnic systems including utcmes than in the claims used fr mst quality reprting tday; Supprt use f that richer data fr brader and faster quality imprvement; and Substantially imprve the accuracy f data used fr value-based payments under the Medicare Access & CHIP Reauthrizatin Act (MACRA) and ther pay-fr-perfrmance prgrams. NCQA is wrking tward multiple slutins t achieve these imprtant gals. The first f these is ur emeasure Certificatin prgram, which tests a system s ability t prduce valid perfrmance measure results. emeasure Certificatin & Data Intermediaries By using industry standards t test target systems, NCQA s certificatin helps t ensure that when a clinician is crrectly dcumenting care with their electrnic health recrd (EHR), they can be assured the certified system will be interperable with ther EHR mdules and accurately reprt perfrmance. The burden f the clinician is minimized because the data needed t reprt quality measures shuld be autmated as a result f the validated interperability and reprting tests that NCQA cnducts. Here s hw it wrks: 1. NCQA s emeasure Certificatin evaluates a target system s ability t ingest cntinuity f care dcuments (CCDs) the equivalent f the medical recrd. 2. The prgram expects the target system t parse thrugh data prvided t them by NCQA and accurately identify the crrect recrds that meet a given measure specificatin. 3. The system must then be able t send NCQA the crrect recrds in QRDA 1 and QRDA 3 frmats. These are the frmats used fr the Healthcare Effectiveness Data & Infrmatin Set (HEDIS ), Medicare Stars, and ther ambulatry quality reprting prgrams.
Relying n this certificatin will facilitate greater autmatin in quality reprting. Fr example, nce a data intermediary such as a Qualified Clinical Data Registry (QCDR) achieves certificatin, it can autmatically pull the crrect data frm a clinician s EHR t build a reliable and valid perfrmance measure. This takes the wrk f measure reprting ut f the clinician s hands and allws them t allcate time therwise spent in frnt f a cmputer t mre time spent in frnt f a patient. Eventually NCQA wants t streamline this prcess even mre. At present, as measure specificatins evlve with clinical guidelines, vendrs must update individual iteratins f their quality reprting sftware. Often the same sftware has hundreds f iteratins at different practices acrss the cuntry, leading t significant administrative burden fr bth vendrs and practice managers. NCQA is trying t change that. Our gal is t intervene upstream f this prblem by wrking directly with ur certified data intermediaries, such as QCDRs, t update measure specificatins within their sftware instead f the individual EHR installatins. In this new wrld, the data intermediaries wuld cntinue t pull data frm EHRs as they nrmally wuld. Hwever, because we can wrk directly with the intermediaries t ensure their measure specificatins are up-t-date, vendrs and practices managers wuld n lnger be respnsible fr burdensme updates t quality reprting sftware. MACRA Reprting Burden The ther area we believe yu culd reduce burden n prviders is related t participatin in QPP particularly n the Merit-Based Incentive Payment System (MIPS) track. Under MIPS, Patient-Centered Medical Hmes (PCMHs) and Patient-Centered Specialty Practices (PCSPs) receive aut-credit fr the Imprvement Activities prtin f the MIPS scre. We believe yu shuld als prvide Advancing Care Infrmatin aut-credit t PCMHs and PCSPs because f the strng fcus n use f HIT in standards fr these prgrams. ACI aut-credit wuld reduce unnecessary burden fr clinicians wh have already cmpleted the rigrus PCMH r PCSP recgnitin prcess. Recgnized clinicians have demnstrated t NCQA fr a perid f at least 90 days hw they use HIT t imprve patient care, and must update NCQA annually n perfrmance in key areas t maintain recgnitin. Appendices A & B crsswalk the substantial verlap between HIT prvisins in NCQA PCMH and PCSP standards and ACI requirements and measures. Thank yu fr the pprtunity t prvide feedback. We lk frward t cllabrating with yu t meaningfully reduce administrative burden while als imprving the accuracy and efficiency f perfrmance measurement. If yu have any questins, please cntact Paul Cttn, Directr f Federal Affairs, at cttn@ncqa.rg r (202) 955 5162. Sincerely, Margaret O Kane, President 2
Appendix A Advancing Care Infrmatin & NCQA PCMH Advancing Care Infrmatin Measure Security Risk Analysis e-prescribing Prvide Patient Access Send a Summary f Care NCQA PCMH Standard Team-Based Care & Practice Organizatin - Standard 5: The practice uses an EHR system (r mdules) that has been certified and issued an ONC Certificatin ID, cnducts a security risk analysis, and implements security updates as necessary crrecting identified security deficiencies. Knwing and Managing Yur Patients - Standard 19: Systematically btains prescriptin claims data in rder t assess and address medicatin adherence. Patient-Centered Access and Cntinuity - Standard 5: Dcuments clinical advice in patient recrds and cnfirms clinical advice and care prvided after-hurs des nt cnflict with patient medical recrd. - Standard 7: Has a secure electrnic system fr patient t request appintments, prescriptin refills, referrals and test results. Care Crdinatin and Care Transitins - Standard 4 (A-C): The practice systematically manages referrals by: A. Giving the cnsultant r specialist the clinical questin, the required timing and the type f referral; B. Giving the cnsultant r specialist pertinent demgraphic and clinical data, including test results and the current care plan; C. Tracking referrals until the cnsultant r specialist s reprt is available, flagging and fllwing up n verdue reprts. - Standard 15: Shares clinical infrmatin with admitting hspitals and emergency departments. - Standard 18: Exchanges patient infrmatin with the hspital during a patient s hspitalizatin. - Standard 21 (C): Demnstrates electrnic exchange f infrmatin with external entities, agencies and registries: C. Summary f care recrd t anther prvider r care facility fr care transitins. 3
Appendix A Advancing Care Infrmatin & NCQA PCMH Advancing Care Infrmatin Measure Request/Accept Summary f Care Patient-Specific Educatin View, Dwnlad and Transmit (VDT) Secure Messaging NCQA PCMH Standard Care Crdinatin and Care Transitins - Standard 18: Exchanges patient infrmatin with the hspital during a patient s hspitalizatin. - Standard 19: Implements a prcess t cnsistently btain patient discharge summaries frm the hspital and ther facilities. - Standard 21 (C): Demnstrates electrnic exchange f infrmatin with external entities, agencies and registries: C. Summary f care recrd t anther prvider r care facility fr care transitins. Knwing and Managing Yur Patients - Standard 8: Evaluates patient ppulatin demgraphics/cmmunicatin preferences/health literacy t tailr develpment and distributin f patient materials. - Standard 16: Assesses understanding and prvides educatin, as needed, n new prescriptins fr mre than 50 percent f patients/families/caregiver. - Standard 21: Uses infrmatin n the ppulatin served by the practice t priritize needed cmmunity resurces. - Standard 22: Prvides access t educatinal resurces, such as materials, peersupprt sessins, grup classes, nline self-management tls r prgrams. Patient-Centered Access and Cntinuity - Standard 5: Dcuments clinical advice in patient recrds and cnfirms clinical advice and care prvided after-hurs des nt cnflict with patient medical recrd. - Standard 7: Has a secure electrnic system fr patient t request appintments, prescriptin refills, referrals and test results. Patient-Centered Access and Cntinuity - Standard 5: Dcuments clinical advice in patient recrds and cnfirms clinical advice and care prvided after-hurs des nt cnflict with patient medical recrd. - Standard 8: Has a secure electrnic system fr tw-way cmmunicatin t prvide timely clinical advice. 4
Appendix A Advancing Care Infrmatin & NCQA PCMH Advancing Care Infrmatin Measure Patient-Generated Health Data Clinical Infrmatin Recnciliatin Immunizatin Registry Reprting NCQA PCMH Standard Care Management and Supprt - Standard 7: Identifies and discusses ptential barriers t meeting gals in individual care plans. - Standard 8: Includes a self-management plan in individual care plans. - Standard 9: Care plan is integrated and accessible acrss settings f care. Knwing and Managing Yur Patients - Standard 14: Reviews and recnciles medicatins fr mre than 80 percent f patients received frm care transitins. Care Crdinatin and Care Transitins - Standard 20: Cllabrates with the patient/family/caregiver t develp/implement a written care plan fr cmplex patients transitining int/ut f the practice (e.g., frm pediatric care t adult care). Care Crdinatin and Care Transitins - Standard 21 (B): Demnstrates electrnic exchange f infrmatin with external entities, agencies and registries: B. Immunizatin registries r immunizatin infrmatin systems. 5
Appendix B Advancing Care Infrmatin & NCQA PCSP Advancing Care Infrmatin Measure Security Risk Analysis e-prescribing Prvide Patient Access NCQA PCSP Dmain & Element Measure and Imprve Perfrmance - Element E: Use Certified EHR Technlgy. The practice uses a certified EHR system: The practice attests t cnducting a security risk analysis f its EHR system (r mdules) and implementing security updates as necessary and crrecting identified security deficiencies. Plan and Manage Care - Element C: Use Electrnic Prescribing. The practice uses an electrnic prescriptin system with the fllwing capabilities: At least 75 percent f eligible prescriptins are generated using the electrnic prescriptin system. Mre than 50 percent f eligible prescriptins written by the practice are cmpared t drug frmularies and sent t pharmacies electrnically. Mre than 60 percent f medicatin rders are entered int the medical recrd. Prvide Access and Cmmunicatin - Element B: Electrnic Access. The practice prvides the fllwing infrmatin and services t patients/ families/caregivers thrugh a secure electrnic system: Mre than 50 percent f patients have timely access t their health infrmatin. The capability t view, dwnlad r transmit their health infrmatin t a third party. 6
Appendix B Advancing Care Infrmatin & NCQA PCSP Advancing Care Infrmatin Measure Send a Summary f Care NCQA PCSP Dmain & Element Wrking with Primary Care and Other Referring Clinicians - Element D: Assessing Initial Referral Respnse. The practice has a written prcess and mnitrs against it t ensure a timely respnse t PCPs and referring clinicians that includes: Electrnic transmissin f a summary f care recrd t anther prvider, fr mre than 10 percent f referrals. - Element F: Cnnecting Patients With Primary Care. The practice implements a dcumented prcess fr cnnecting self-referred patients with primary care clinicians that includes: Fr self-referred patients with a primary care clinician, prviding a summary f care reprt t the primary care clinician. Track and Crdinate Care - Element B: Referral Tracking and Fllw-Up. The practice crdinates referrals t ther (secndary) specialists by: Demnstrating its capability t prvide an electrnic summary-f-care recrd t anther prvider fllwing a referral. Electrnically transmitting a summary-f-care recrd t anther care prvider, fr mre than 10 percent f care referrals. - Element C: Crdinate Care Transitins. The practice supprts patients wh have an nging relatinship with a specialist during acute care transitins. Fr these patients, the practice systematically: Demnstrates its capability t prvide an electrnic summary f care recrd t anther facility fllwing a transitin f care. Electrnically transmits a summary f care recrd t anther care setting fr mre than 10 percent f care transitins. 7
Appendix B Advancing Care Infrmatin & NCQA PCSP Advancing Care Infrmatin Measure Request/Accept Summary f Care Patient-Specific Educatin View, Dwnlad and Transmit (VDT) Secure Messaging NCQA PCSP Dmain & Element Track and Crdinate Care - Element B: Referral Tracking and Fllw-Up. The practice crdinates referrals t ther (secndary) specialists by: Fllwing up t btain the specialist s reprt. Asking patients/families/caregivers abut self-referrals and requesting reprts frm clinicians. - Element C: Crdinate Care Transitins. The practice supprts patients wh have an nging relatinship with a specialist during acute care transitins. Fr these patients, the practice systematically: Demnstrates its prcess fr cnsistently btaining patient discharge summaries frm the hspital and ther facilities. Plan and Manage Care - Element A: Care Planning and Supprt Self-Care. The practice prvides the fllwing care management and self-care supprt fr practice-specific cnditins: Uses an EHR t identify and prvide patient-specific educatin resurces t mre than 10 percent f patients. Prvide Access and Cmmunicatin - Element B: Electrnic Access. The practice prvides the fllwing infrmatin and services t patients/ families/caregivers thrugh a secure electrnic system: Mre than 50 percent f patients have timely access t their health infrmatin. The capability t view, dwnlad r transmit their health infrmatin t a third party. Prvide Access and Cmmunicatin - Element B: Electrnic Access. The practice prvides the fllwing infrmatin and services t patients/ families/caregivers thrugh a secure electrnic system: The capability t send a secure message. Tw-way cmmunicatin between patients/families/caregivers and the practice. Requests fr appintments, prescriptin refills, referrals and test results. 8
Appendix B Advancing Care Infrmatin & NCQA PCSP Advancing Care Infrmatin Measure Patient-Generated Health Data Clinical Infrmatin Recnciliatin Immunizatin Registry Reprting NCQA PCSP Dmain & Element N analgus standard at this time. - With apprval frm CMS, we can develp this as a part f an ACI deeming mdule fr PCSP. Plan and Manage Care - Element B: Medicatin Management. The practice has a prcess and demnstrates that it systematically manages medicatins prescribed by the practice in the fllwing ways: Recnciles medicatins fr mre than 50 percent f patients received frm anther care setting r at a relevant visit. Wrking With Primary Care and Other Referring Clinicians - Element C: Assessing Initial Referral Cntent. The practice sets expectatins and mnitrs against thse expectatins t cnfirm receipt f infrmatin needed in referrals frm clinicians: Clinical questins t be answered by the referral. Type f referral. Urgency f referral. Patient demgraphics. Clinical infrmatin. Current primary practice care plan, treatment, test results and prcedures. Which clinician is respnsible fr cmmunicating with patient/family/ caregiver. Measure and Imprve Perfrmance - Element E: Use Certified EHR Technlgy. The practice uses a certified EHR system: The practice demnstrates the capability t submit electrnic data t immunizatin registries r immunizatin infrmatin systems. 9