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The COVID pandemic highlighted health care inequities like no other event in our current history. In late 2021, the National Academy of Medicine convened U.S. health care quality organizations to discuss the most important priorities for the healthcare quality movement in the next 20 years. The resulting paper identified the urgent need to collect race, ethnicity and other data (like gender identity, LGBTQIA, etc) uniformly across the system.
Once that data is collected, the authors note, the work of segmenting populations for true action can be taken, an example of such data use is captured below:
In our last blog, we noted the foundations that the Department of Health & Human Services (HHS) has set to advance equity across the department, and the Centers for Medicaid & Medicare Services (CMS) follow-on Framework for Health Equity. CMS’ strategy is focused on identifying and responding to inequities in health outcomes, barriers to coverage and access to care.
The National Committee for Quality Assurance (NCQA) and other measure stewards continue to support this direction set by the Administration by measuring health plans, providers and other stakeholders’ ability to impact health equity.
Data Collection & Intervention
In 2021, NCQA introduced race and ethnicity stratifications to five measures for measurement year 2022 (MY 2022):
NCQA plans to expand race and ethnicity stratifications to at least 15 measures total by MY2024.
In 2022, NCQA has continued its commitment to measuring, understanding and impacting health equity in quality of care. In April of this year, NCQA finalized the list of measures for Health Plan Reporting 2023, which is based on MY 2022.
This list included a new measure: Race/Ethnicity Diversity of Membership (RDM) which has been created in order to understand the racial and ethnic composition of a health plan’s membership. Race and Ethnicity designations align with the Office of Management and Budget Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity.
In this time period, NCQA also released proposed updates and changes to HEDIS(R) measures for Measurement Year 2023 (MY2023). Some of these updates highlight the organization's focus on equity, including a proposed Social Need Screening and Intervention (SNS-E) measure and expanding the race and ethnicity stratification to at least 5 more measures across several domains. These proposed updates address both data collection and intervention on social needs.
The Medicare Advantage 2023 Announcement similarly proposed stratified reporting by disability, low-income subsidy status and dual eligibility status. CMS also proposed the development of a health equity index, summarizing performance into a single score within each contract and adding a Screening and Referral to Services for Social Needs measure to the Display Page.
CMS and NCQA are aligned in their efforts. For example, CMS proposed to amend § 422.101(f)(1)(i) to require that all Medicare Advantage Special Needs Plans (SNPs) include one or more standardized questions on the topics of housing stability, food security, and access to transportation as part of their annual health risk assessments. This proposal aligns with NCQA’s proposed Social Need Screening and Intervention HEDIS measure perfectly.
Similarly, CMS finalized the Quality Improvement Strategy (QIS) Standards that requires Qualified Health Plans (QHP) participating in a Marketplace for two or more consecutive years to implement and report on a QIS that includes at least one topic area defined in section 1311(g)(1) of the ACA (activities to improve health outcomes, prevent hospital readmissions, improve patient safety and reduce medical errors, promote wellness and health and reduce health and health care disparities).
The Administration, measure stewards like NCQA and other healthcare stakeholders are creating the foundations needed to measure and truly impact social drivers of health.
What’s Next for Plans & Providers
For health plans and providers, focusing on health equity, capturing social drivers of health data, and addressing inequities within care and services is critical across government markets, including managed Medicaid, Medicare Advantage and ACA plans.
Plans must begin collecting race and ethnicity data in as standard a format as possible. Follow the Administration’s lead in how to categorize and segment race and ethnicity. Secondly, begin to look at all key performance indicators (KPI) - if possible - by race and ethnicity, as well as other factors like language spoken. These data points will highlight additional areas requiring attention.
In terms of collecting SDoH data, start small and start local. Understand the needs of the community in which you operate - housing, unemployment, childcare, food/nutrition - and begin asking questions about those areas of life. Lean on your digital partners to gather this information without over-burdening members with phone calls and flyers.
As healthcare providers consistently track race, ethnicity and other socio-demographic data, more can be understood about the needs and challenges of beneficiaries. Read our last blog for implementation considerations, including improving relationships locally, data sharing and embarking on digital partnerships.
