HEDIS®1 Public Comment Overview HEDIS Overview HEDIS is a set of standardized performance measures designed to ensure that purchasers and consumers can reliably compare the performance of health plans. It also serves as a model for emerging systems of performance measurement in other areas of health care delivery. HEDIS is maintained by NCQA, a not-for-profit organization committed to evaluating and publicly reporting on the quality of health plans, ACOs, physicians, and other organizations. The HEDIS measurement set consists of 92 measures across 6 domains of care. Items available for public comment are being considered for HEDIS Measurement Year 2022, which will be published in August 2021. HEDIS Measure Development Process NCQA’s consensus development process involves rigorous review of published guidelines and scientific evidence, as well as feedback from multi-stakeholder advisory panels. The NCQA Committee on Performance Measurement, a diverse panel of independent scientists and representatives from health plans, consumers, federal policymakers, purchasers and clinicians, oversees the evolution of the HEDIS measurement set. Numerous measurement advisory panels provide clinical and technical knowledge required to develop the measures. Additional HEDIS expert panels and the Technical Measurement Advisory Panel provide invaluable assistance by identifying methodological issues and giving feedback on new and existing measures. Synopsis NCQA seeks public feedback on proposed new HEDIS measures, revisions to existing measures and proposed measure retirement. Reviewers are asked to submit comments to NCQA in writing via the Public Comment website by 11:59 p.m. (ET), Thursday, March 11. Submitting Comments Submit all comments via NCQA’s Public Comment website at https://my.ncqa.org/ Note: NCQA does not accept comments via mail, email or fax. 1HEDIS® is a registered trademark of the National Committee for Quality Assurance (NCQA). How to Submit a Comment 1. Go to https://my.ncqa.org/. 2. Once logged in, click to select Public Comment. 3. Click Add Comment. 4. In the Product field, click to select HEDIS Public Comment from the drop-down menu. 5. Click the Instructions link to view public comment materials, including instructions and proposed measure specifications. 6. Click to select the Topic and Element (measure) on which you want to comment. 7. Click to select your support option (e.g., Support, Do not support, Support with modifications). Note: If you chose Do not support, include the reason in the text box. If you chose Support with modifications, enter the suggested modifications in the text box. 8. Enter comments in the Comments box. Note: Comments may not be more than 2,500 characters. We suggest you develop comments in Word to check your character limit and save a copy for reference. Use the “cut and paste” function to copy your comment into the Comments box. 9. Click Submit after each comment. After you have submitted all comments, click Close. You will be able to view and download all your submitted comments. All comments are due Thursday, March 11, by 11:59 PM ET. NCQA Review of Public Comments NCQA appreciates the time and effort required to submit comments, and reviews all feedback submitted within the public comment period. Due to the high volume of comments received, NCQA cannot respond to individual comments, but NCQA advisory panels and the Committee on Performance Measurement will consider comments and advise NCQA staff. Items for Public Comment Refer to the NCQA Public Comment page for detailed documentation (memos, specifications, performance data) on the items listed below. Future of HEDIS • Introduction of Race and Ethnicity Stratification Into Select HEDIS Measures. • Roadmap for Electronic Clinical Data Systems Reporting Method. Proposed New Measures • Advance Care Planning. • Deprescribing of Benzodiazepines in Older Adults. • Antibiotic Utilization for Acute Respiratory Conditions. Proposed Changes to Existing Measures • Acute Hospital Utilization. • Use of Imaging Studies for Low Back Pain. • Mental Health Utilization. • Identification of Alcohol and Other Drug Services. • Initiation and Engagement of Alcohol and Other Drug Abuse or Dependence Treatment. • Follow-Up After Emergency Department Visit for Alcohol and Other Drug Abuse or Dependence. • Comprehensive Diabetes Care. Proposed Measure Retirement • Comprehensive Diabetes Care—HbA1c Testing. • Antibiotic Utilization. Questions? Contact NCQA Customer Support at 888-275-7585, Monday–Friday, 8:30 a.m.–5:00 p.m. (ET). Proposed Changes to Existing Measures for HEDIS®1 MY 2022: Introduction of Race and Ethnicity Stratification Into Select HEDIS Measures NCQA seeks comments on the proposed addition of race and ethnicity stratifications to select HEDIS measures beginning in measurement year (MY) 2022. NCQA’s goal is to advance health equity by leveraging HEDIS to hold health plans accountable for disparities in care among their patient populations. This includes bringing transparency to where gaps exist (or do not exist) and highlighting plans that successfully invest in strategies to reduce disparities in care and outcomes. Based on feedback from expert panels, the NCQA team developed a 3-year phased approach for implementing the stratifications, with a stated goal of requiring all plans to report measure performance by race and ethnicity using directly collected2 member data by MY 2024. In MY 2022 and MY 2023, plans that meet a direct data completeness threshold of 80% for race and 80% for ethnicity will be allowed to report the stratification using their own directly collected member data for race and ethnicity. Direct data is the gold standard. Note: NCQA’s proposal is to implement indirect data for population level analysis; we recognize that indirect data is likely to be inappropriate for patient-level intervention. It is our opinion that indirect data provides a path toward transparency on disparities in quality of care in the near term. Plans that do not meet the data completeness threshold will be required to report the stratification using an approved method of indirect race and ethnicity assignment. NCQA is currently evaluating two potential approaches to specifying this stratification (Attachment). The approaches are consistent in the approved methods of direct and indirect data collection, but differ in the level at which the direct data completeness threshold must be met: • Option 1: Require data completeness at the measure level. In this approach, plans must meet the data completeness threshold for the eligible population of each measure to which this stratification applies in order to report using direct data for each measure. • Option 2: Require data completeness at the plan level. In this approach, plans must meet the data completeness threshold across their enrollment in order to report using direct data for all measures to which this stratification applies. NCQA proposes that race and ethnicity stratifications are reported separately. NCQA also proposes to define race and ethnicity categories according to existing HEDIS descriptive measure Race/Ethnicity Diversity of Membership (RDM), which aligns with Office of Management and Budget categories (Attachment). NCQA seeks general feedback on the proposal above and on the following: 1. Measures listed as candidates for stratification in MY 2022 (Attachment). In selecting these measures, NCQA evaluated them on a set of criteria, including the extent of known disparities by race and ethnicity in a particular health issue, areas that have been prioritized in state equity efforts, and whether a measure could be expected to yield small denominators if stratified. NCQA also sought to cover a wide range of health topics and include measures reported by all product lines (Medicare, Medicaid, commercial). 1 HEDIS® is a registered trademark of the National Committee for Quality Assurance (NCQA). 2 In developing our recommended approach, NCQA considered multiple options for implementing this stratification in HEDIS, taking into account the importance of moving toward direct data, as well as limitations of the current data environment and feasibility for implementation. In alignment with the current RDM measure, NCQA defines direct data collection as data collected directly from members (e.g., surveys, health risk assessments, disease management registries, CMS/state databases) or from enrollment information furnished by state Medicaid agencies. Indirect methods involve imputing race/ethnicity through methods such as surname analysis and geo-coding. 2. The timeline for introducing the race and ethnicity stratification to measures. A target of 5 measures will be stratified in MY 2022, with a minimum of 15 measures stratified by MY 2024. NCQA will convene a Health Equity Expert Work Group throughout 2021 to gather ongoing feedback as we review public comment responses and finalize the stratification specification. 3. Thoughts on additional measures that should be prioritized for future stratification. 4. Concerns regarding feasibility for direct/indirect methods. NCQA welcomes feedback on the details and implications of these methods. Supporting documents include the draft stratification options, the list of candidate measures and evidence workup. NCQA acknowledges the contributions of the Health Equity Expert Work Group and the internal Measures Policy team for their input and work on these proposed race/ethnicity stratifications. Race/Ethnicity Stratification Options for MY 2022 Description