ACAP Comments on Proposed 2019 HEDIS/CAHPS Measures for HPA Scoring

December 15, 2017

Submitted electronically via http://publiccomments.ncqa.org/

Partial Removal

Antidepressant Medication Management (AMM)—Acute Phase Rate
Support

Initiation and Engagement of Alcohol and Other Drug Dependence Treatment (IET)—Initiation Rate
Do not support
ACAP does not support removing the initiation phase portion of this measure, while keeping the continuation portion. Because of the critical nature of initiation for this measure and the difficulty in impacting initiation, we cannot understand or support removing the initiation and keeping only the continuation portion of the measure. The initiation rate more accurately represents a health plan’s ability to identify and engage a difficult-to-reach population of patients; initiation into treatment is a necessary first step that engagement is predicated on. In fact, given issues such as churn in the Medicaid program, and the difficulties getting individuals to initiate treatment and the importance of doing so, a better approach would be to remove the engagement rate and report solely on the initiation measure.
As a general matter, given the use of HEDIS measures in Medicaid PIPs, value-based contracting approaches, etc., we strongly suggest that NCQA consult with Medicaid Directors before making changes in the measure set used for accreditation scoring in order to support alignment regarding the use of HEDIS measures.
In addition, we strongly advocate that NCQA issues not only the measure changes for comment but also the scoring changes as well. How the points will be allocated/reallocated is as important as the measures themselves and should be subject to public input.

Statin Therapy for Patients with Cardiovascular Disease (SPC)—Received Statin Therapy Rate
Support
ACAP does not oppose removing this measure. However, given that the denominator for the adherence rate is those who are receiving statin therapy, we do have a concern that using the adherence rate alone will not capture those individuals who would benefit from receiving statins but are not.
As a general matter, given the use of HEDIS measures in Medicaid PIPs, value-based contracting approaches, etc., we strongly suggest that NCQA consult with Medicaid Directors before making changes in the measure set used for accreditation scoring in order to support alignment regarding the use of HEDIS measures.
In addition, we strongly advocate that NCQA issues not only the measure changes for comment but also the scoring changes as well. How the points will be allocated/reallocated is as important as the measures themselves and should be subject to public input.

Statin Therapy for Patients with Diabetes (SPD)—Received Statin Therapy Rate
Support
ACAP does not oppose removing this measure. However, given that the denominator for the adherence rate is those who are receiving statin therapy, we do have a concern that using the adherence rate alone will not capture those individuals who would benefit from receiving statins but are not.
As a general matter, given the use of HEDIS measures in Medicaid PIPs, value-based contracting approaches, etc., we strongly suggest that NCQA consult with Medicaid Directors before making changes in the measure set used for accreditation scoring in order to support alignment regarding the use of HEDIS measures.
In addition, we strongly advocate that NCQA issues not only the measure changes for comment but also the scoring changes as well. How the points will be allocated/reallocated is as important as the measures themselves and should be subject to public input.

Follow-Up for Children Prescribed ADHD Medication (ADD)—Initiation Phase Rate
Do not support
ACAP does not support removing the initiation phase portion of this measure, while keeping the engagement portion. We believe both portions of the measure are important and measure different but complementary components.
ACAP recognizes and supports the need for monitoring follow-up, and emphasizes the utility of collecting information for children who have remained on ADHD medication beyond the initial initiation phase. However, we believe that focusing on follow-up rate without regard for the initiation phase rate would limit the usefulness of this measure. The initiation phase rate more accurately represents a health plan’s ability to identify and begin to engage children who are prescribed medication; initiating medication is a necessary first step that future follow-up is predicated on. In addition, continuing to capture and report the rates of children in the initiation phase is critical for a Medicaid health plan because of the high levels of churn within the program that may prevent plans from monitoring children for longer-term follow-up.
As a general matter, given the use of HEDIS measures in Medicaid PIPs, value-based contracting approaches, etc., we strongly suggest that NCQA consult with Medicaid Directors before making changes in the measure set used for accreditation scoring in order to support alignment regarding the use of HEDIS measures.
In addition, we strongly advocate that NCQA issues not only the measure changes for comment but also the scoring changes as well. How the points will be allocated/reallocated is as important as the measures themselves and should be subject to public input.

Weight Assessment and Counseling for Nutrition and Physical Activity for Children/Adolescents (WCC)—Counseling for Physical Activity and Counseling for Nutrition Rates
Support with modifications
ACAP clearly recognizes the growing epidemic of childhood obesity and the need for ongoing counseling around physical activity and nutrition. ACAP and its member plans care deeply about childhood obesity as a public health issue and advocate that it remains a critical component of the measure sets.
Given that BMI measurement is the highest in terms of rates for the 3 measures in this measure cohort, it is clear that there is still room for improvement in regard to the counseling measures. However, we also recognize the difficulty with the subjective nature of the chart review required with this measure and suspected variability. Therefore, we can understand why NCQA might want to remove this measure.  It should be noted that we believe such action should only be taken if NCQA is actively pursuing another way to address this issue in future measurement.
As a general matter, given the use of HEDIS measures in Medicaid PIPs, value-based contracting approaches, etc., we strongly suggest that NCQA consult with Medicaid Directors before making changes in the measure set used for accreditation scoring in order to support alignment regarding the use of HEDIS measures.
In addition, we strongly advocate that NCQA issues not only the measure changes for comment but also the scoring changes as well. How the points will be allocated/reallocated is as important as the measures themselves and should be subject to public input.

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