policy

Utilization of the PHQ-9 to Monitor Depression Symptoms for Adolescents and Adult – Do not support

ACAP supports the need to develop measures to improve the utilization of depression monitoring tools and appropriate treatment and treatment modifications. However, we do not support the measures as proposed.

We understand and support the need for outcomes measures, but we believe the most successful route to reaching quality improvement goals has been to start with the measure that stresses the process, and then moving to stress the outcome. This would allow plans to focus on working with providers to become well-versed with the use of the PHQ before focusing on the impact on depression scores.

The initial focus should be on the use of the depression screening tool once in the measurement year, instead of once in each of the assessment periods. We also question whether the standard of care supports depression testing this frequently for all patients. We believe that other depression measurement tools that are more appropriate for some populations should also be recognized.

ACAP does not support a required measure that that relies solely on ECDS data. While the adoption of EMR by providers serving the Medicaid population has and continues to increase, it is by no means utilized by a substantial number of small and behavioral health practices that are still a significant part of the Medicaid provider network. In addition, with the use of assessment periods, scores will be substantially lower if the EMR has not been operating for the entire year.

Due to ongoing interoperability issues, plans are not all able to collect ECDS. Many health plans are provided access to limited data streams to support HEDIS data collection. This will require providers to alter the feed to accommodate additional elements. In addition, in many EMRs, PHQ screening documents and scores are added as scanned documents not as a data element. We assume for those plans that do get this data from ECDS will be scored zero or N/A for all components of the measure suite.

There is also the issue of mental health carve outs that impact a plans ability to collect this data from behavioral health providers.

We appreciate and support the learning collaborative focused on the voluntary collection of measures that rely on ECDS.

Finally, in order to encourage the use of ECDS to support HEDIS measurement in general, NCQA should eliminate confusion and clarify for all plans and auditors the role ECDS data can play as a supplemental data source for all HEDIS measures.

 

Depression Remission, Response or Treatment Adjustment for Adolescents and Adults – Do not support

ACAP supports the need to develop measures to improve the utilization of depression monitoring tools and appropriate treatment and treatment modifications. However, we do not support the measures as proposed.

We understand and support the need for outcomes measures, but we believe the most successful route to reaching quality improvement goals has been to start with the measure that stresses the process, and then moving to stress the outcome. This would allow plans to focus on working with providers to become well-versed with the use of the PHQ before focusing on the impact on depression scores.

ACAP does not support a required measure that that relies solely on ECDS data. While the adoption of EMR by providers serving the Medicaid population has and continues to increase, it is by no means utilized by a substantial number of small practices that are still a significant part of the Medicaid provider network. In addition, with the use of assessment periods, scores will be substantially lower if the EMR has not been operating for the entire year.

Due to ongoing interoperability issues, plans are not all able to collect ECDS. Many health plans are provided access to limited data streams to support HEDIS data collection. This will require providers to alter the feed to accommodate additional elements. In addition, in many EMRs, PHQ screening documents and scores are added as scanned documents not as a data element. We assume for those plans that do get this data from ECDS will be scored zero or N/A for all components of the measure suite.

There is also the issue of mental health carve outs that impact a plans ability to collect this data from behavioral health providers.

We also question the appropriateness of the required percentage response to treatment. ACAP would support monitoring response based on a reduction of points from baseline.

Finally, in order to encourage the use of ECDS to support HEDIS measurement in general, NCQA should eliminate confusion and clarify for all plans and auditors the role ECDS data can play as a supplemental data source for all HEDIS measures.

 

Depression Screening and Follow-up for Adolescents and Adults – Do not support

ACAP supports the need to develop measures to improve the utilization of depression monitoring tools and appropriate treatment and treatment modifications. However, we do not support the measures as proposed.

We understand and support the need for outcomes measures, but we believe the most successful route to reaching quality improvement goals has been to start with the measure that stresses the process, and then moving to stress the outcome. This would allow plans to focus on working with providers to become well-versed with the use of the PHQ before focusing on the impact on depression scores.

ACAP does not support a required measure that that relies solely on ECDS data. While the adoption of EMR by providers serving the Medicaid population has and continues to increase, it is by no means utilized by a substantial number of small practices that are still a significant part of the Medicaid provider network. In addition, with the use of assessment periods, scores will be substantially lower if the EMR has not been operating for the entire year.

Due to ongoing interoperability issues, plans are not all able to collect ECDS. Many health plans are provided access to limited data streams to support HEDIS data collection. This will require providers to alter the feed to accommodate additional elements. In addition, in many EMRs, PHQ screening documents and scores are added as scanned documents not as a data element. We assume for those plans that do get this data from ECDS will be scored zero or N/A for all components of the measure suite.

There is also the issue of mental health carve outs that impact a plans ability to collect this data from behavioral health providers.

We also question the appropriateness of the required percentage response to treatment. ACAP would support monitoring response based on a reduction of points from baseline.

Finally, in order to encourage the use of ECDS to support HEDIS measurement in general, NCQA should eliminate confusion and clarify for all plans and auditors the role ECDS data can play as a supplemental data source for all HEDIS measures.

 

Inpatient Hospital Utilization – Support with Modification

We applaud the NCQA move to utilize risk adjustment for hospital and emergency department utilization measures in Medicare. However, we do not believe that the NCQA action goes far enough.

We believe that more should be done to risk adjust these measures based on socioeconomic status. At a minimum strongly advocate that NCQA separately report and compare HEDIS measures for D-SNPs from the measures reported for the Medicare Advantage program. By definition, D-SNPs are serving a different and more challenging population – lower income elderly and disabled individuals that experience multiple chronic conditions, have higher rates of behavioral health needs and are dealing with the day-to-day challenges associated with a lower economic status. In order to address quality care and health outcomes for the D-SNP population, health plans must first spend significant efforts to address social determinants of health and impacts of social economic status on health in a way that is not encountered in the Medicare Advantage program.

ACAP wants to be clear that we do support quality measurement and the identification of how health plans are faring against the benchmarks for each measure. However, these benchmarks should be based on the performance of other D-SNPS and measurement should be based on serving a like population.

Emergency Department Utilization – Support with Modification

We applaud the NCQA move to utilize risk adjustment for hospital and emergency department utilization measures in Medicare. However, we do not believe that the NCQA action goes far enough.

We believe that more should be done to risk adjust these measures based on socioeconomic status. At a minimum strongly advocate that NCQA separately report and compare HEDIS measures for D-SNPs from the measures reported for the Medicare Advantage program. By definition, D-SNPs are serving a different and more challenging population – lower income elderly and disabled individuals that experience multiple chronic conditions, have higher rates of behavioral health needs and are dealing with the day-to-day challenges associated with a lower economic status. In order to address quality care and health outcomes for the D-SNP population, health plans must first spend significant efforts to address social determinants of health and impacts of social economic status on health in a way that is not encountered in the Medicare Advantage program.

ACAP wants to be clear that we do support quality measurement and the identification of how health plans are faring against the benchmarks for each measure. However, these benchmarks should be based on the performance of other D-SNPS and measurement should be based on serving a like population.

 

Statin Therapy for Patients with Cardiovascular Disease – Support with Modifications

ACAP supports this measure with modification. It is based on the premise that all individuals with Cardiovascular Disease must be on moderate level statin. However, it does not adequately address the situation where an individual is well-controlled by the use of a lowerlevel statin. Therefore, we support modifying the measure to accept this approach as appropriate.

We also question the use of different age groups by gender and would like to see more justification as to the evidence base compared to the confusion that it may cause at the practice level.

 

Statin Therapy for Patients with Diabetes – Do not support

We not support the addition of this measure at this time. We believe it is more appropriate to spend health plan quality improvement efforts to address the existing outcome measures.

 

Hospitalization for Potentially Preventable Complications – Support with Modifications

We believe that more should be done to risk adjust these measures based on socioeconomic status. At a minimum strongly advocate that NCQA separately report and compare HEDIS measures for D-SNPs from the measures reported for the Medicare Advantage program. By definition, D-SNPs are serving a different and more challenging population – lower income elderly and disabled individuals that experience multiple chronic conditions, have higher rates of behavioral health needs and are dealing with the day-to-day challenges associated with a lower 5 economic status. In order to address quality care and health outcomes for the D-SNP population, health plans must first spend significant efforts to address social determinants of health and impacts of social economic status on health in a way that is not encountered in the Medicare Advantage program.

ACAP wants to be clear that we do support quality measurement and the identification of how health plans are faring against the benchmarks for each measure. However, these benchmarks should be based on the performance of other D-SNPS and measurement should be based on serving a like population. Asthma Medication Ratio – Support with Modifications ACAP continues to have concerns with this measure. Most notably, we are concerned that COPD diagnoses will be miscoded as asthma and inappropriately included in the denominator. As currently designed, there is no methodology for health plans to appropriately exclude those misdiagnosed when found and addressed by the practitioner.

 

Medication Management for People with Asthma- Support

No comment

 

Medication Reconciliation Post-Discharge – Support with Modification

We believe that more should be done to risk adjust these measures based on socioeconomic status. At a minimum strongly advocate that NCQA separately report and compare HEDIS measures for D-SNPs from the measures reported for the Medicare Advantage program. By definition, D-SNPs are serving a different and more challenging population – lower income elderly and disabled individuals that experience multiple chronic conditions, have higher rates of behavioral health needs and are dealing with the day-to-day challenges associated with a lower economic status. In order to address quality care and health outcomes for the D-SNP population, health plans must first spend significant efforts to address social determinants of health and impacts of social economic status on health in a way that is not encountered in the Medicare Advantage program.

ACAP wants to be clear that we do support quality measurement and the identification of how health plans are faring against the benchmarks for each measure. However, these benchmarks should be based on the performance of other D-SNPS and measurement should be based on serving a like population.

 

Use of Appropriate Medications for People with Asthma – Support

We support retirement of this measure.

 

Change in Policy: Measure Rotation – Do not support

We oppose the elimination of the rotation of hybrid measures. For those plans that are utilizing rotation, it allows the plan to focus quality improvement on the measures that need work. While 6 we understand the impact on benchmarking and trending, we believe that can be addressed in other ways.

ACAP recommends that the rotation of hybrid measures still be allowable. However, if the elimination is going to be adopted, it should be phased-out over a period of time. In order to eliminate the potential for gaming, we also support controls on it use – for example, requiring that plans must be in the 75th percentile or above for the measure

 

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