On behalf of the Association for Community Affiliated Plans (ACAP), we appreciate the ability to submit comments on the NCQ Draft Report, Risk Adjustment for Socioeconomic Status or Other Sociodemographic Factors. ACAP is a trade association that represents 56 non-profit safety net health plans serving approximately 10 million publicly individuals in 25 states.
ACAP strongly supports all the Recommendations made by the majority of the Expert Panel. Our organization has long advocated for a system for risk adjusting quality measurement that would result in a more accurate and meaningful measurement.
Our members plan have actually experienced physician practices wanting to avoid or even drop from their patient panels disadvantage patients who may be labeled as non-adherent and/or difficult because of the life challenges they are dealing with because it is the most expedient way to meet performance targets. Risk adjustment methodologies that take these challenges into account when measuring quality would recognize the extraordinary effort that may be required, instead of having the unintended consequence of penalizing the health plan, health systems and providers for providing the much needed care.
Of course, we also agree with the Expert Panel recommendations that risk adjustment should only occur for measures where it is necessary to more accurately reflect quality and not as a means to mask poor quality care.
We also applaud the recommendation that guidelines must indicate the specific intent of the measure development. Far too often, we have encountered purchaser attempts at utilizing measures for purposes beyond the intent of the measure and for which no measure testing has been done. While identifying variations is acceptable and even desired when using a measure for quality improvement purposes, it may not be accurate when utilizing the measure for accountability purposes and to adjust payment (either incentives or deductions).
Finally, we support the need for further study in terms of the appropriate cadre of sociodemographic factors to be utilized. For example, we believe that utilizing a measure of poverty is appropriate but that may not necessarily equate to geography being an appropriate proxy. We also support the call for development strategies for collecting and sharing information on sociodemographic variables and applaud NQF’s recognition that “there is a need for a national effort to collect relevant sociodemographic information in a standardized way that allows for its valid use in adjustment models that will be applied across states and regions”.