policy
ACAP Comments on Proposed 2018 HEDIS-CAHPS for HPA Scoring
ACAP Comments to NCQA
RE: HEDIS/CAHPS Measures for Health Plan Accreditation Scoring
December 16, 2016
ACAP appreciates the opportunity to comment on the HEDIS/CAHPS Measures for Health Plan Accreditation Scoring. The Association for Community Affiliated Plans (ACAP) represents 58 not-for-profit safety net health plans in 28 states that serve more than 17 million enrollees, predominantly enrolled through the Medicaid Program.
HEDIS Additions
- Statin Therapy for Patients With Cardiovascular Disease (SPC) (both rates) Concerning the statin measures, ACAP supports the measure but does not support inclusion in the HPA scoring at this time. This measure is relatively new. ACAP does not support inclusion in the scoring until there is at least 2 years of data established. Health Plans should be allowed to establish a baseline as well as develop and implement a quality improvement plan in response to the baseline data before the measure is included in the scoring. Therefore, we advocate for a delay until 2019.
- Statin Therapy for Patients With Diabetes (SPD) (both rates) Concerning the statin measures, ACAP supports the measure but does not support inclusion in the HPA scoring at this time. This measure is relatively new. ACAP does not support inclusion in the scoring until there is at least 2 years of data established. Health Plans should be allowed to establish a baseline as well as develop and implement a quality improvement plan in response to the baseline data before the measure is included in the scoring. Therefore, we advocate for a delay until 2019.
- Initiation and Engagement of Alcohol and Other Drug Dependence Treatment (IET) (Initiation of AOD Treatment rate) ACAP is concerned that the 14 day limit associated with this measure precludes its use for HPA scoring purposes. ACAP recognizes that the initiation and engagement of AOD treatment remains below anticipated levels. The difficulties plans face are evident by the fact that even the highest performing plans scored at the 48.28 in 2016, a number that fell from the level of 52.57 in 2015 despite the national attention by states, health plans and others on dealing with the crisis of drug and alcohol dependence and improving the integration of physical and behavioral health services. However, there are a number of contributing factors that make the 14 day measure difficult for health plans to impact including lack of access of appropriately licensed facilities that can be recognized by Medicaid and privacy restrictions that limit data sharing with other treating providers that could held to engage members in seeking treatment. Therefore, we do not support the inclusion of this measure for HPA scoring purposes. As an alternative method for addressing this measure, we would support and encourage NCQA to develop and disseminate practical and effective best practices that would assist plans in addressing this critical issue.
- Adherence to Antipsychotic Medications for Individuals with Schizophrenia (SAA) Given the critical nature of this measure, ACAP supports inclusion in the HPA scoring.
HEDIS Deletions
- Comprehensive Diabetes Care (Medical Attention for Nephropathy rate)
Support. - Comprehensive Diabetes Care (HbA1c Poor Control (>9%) rate)
Support.
We again thank you for this opportunity to comment. Please feel free to contact me directly at dkilstein@communityplans.net if you have any questions concerning this response.
Sincerely,
Deborah Kilstein
VP Quality Management and Operational Support