HEDIS^® Public Comment

1.  Concerns with the Value Set Directory (VSD) and codes. Some feedback recommended additional codes to fully capture different types of smoking screening and cessation intervention actions. Some pointed out the implementation burden of codes on providers and health plans.

2.  There was overall support for stratifying to track performance in different age groups in the measure, with mixed feedback on whether age stratification as proposed, or with alternate age groups, would be useful. Suggestions included simplifying the stratification and aligning with tobacco purchasing laws or lung cancer screening guidelines.

3.  Commenters sought clarification on the types of tobacco and nicotine products included in the measure definition.

4.  Commenters recommended excluding patients 66 years or older who are enrolled in Institutional Special-Needs Plans (I-SNP) or institutionalized long-term, and patients under 66 years in palliative care.

2.  NCQA kept the specified age stratification based on evidence and feedback that separating adolescents, adults and older adults can offer valuable population health insights.

3.  NCQA added the language “any commercial tobacco product” to the measure description.

4.  NCQA added palliative care as an exclusion, to align with standards of care. Special-needs and long-term care plans were identified as appropriate to screen, given the adverse health effects of smoking for these populations.

DECISION:
Add the TSC-E measure for MY 2026.

Note: This measure was previously titled Follow-Up After Acute Care Visits for Asthma.

1.  Most comments supported excluding visits among members with a history of cystic fibrosis, emphysema or acute respiratory failure, due to concerns that these conditions require a different treatment approach than asthma.

2.  There was mixed feedback regarding the denominator visit types to include in the measure.

3.  Most comments supported a 30-day follow-up time frame, given health access and availability challenges, but acknowledged that 15 days would be more aligned with clinical guidelines.

2.  NCQA kept urgent care visits in the final measure, given strong recommendations by respiratory experts, who stated that urgent care is frequently used for acute asthma care. Including urgent care in the measure would ensure capture of all acute visits for asthma.

3.  NCQA included a 30-day follow-up time frame in the measure.

4.  NCQA added an asthma diagnosis requirement to the numerator to ensure asthma is addressed during the outpatient follow-up visit.

1.  There was support for the measure intent, but mixed feedback about data availability and data sources. Suggestions were to include functional status assessments as a source for disability information. There was concern about the reliability of self-reported data and the administrative burden of implementing the measure. Some organizations suggested delaying implementation of this measure until further standards for disability data are released, so that the measure can align with those standards.

2.  Some comments did not support the 15-and-older age restriction.

3. There was a variety of feedback regarding disability type categories. Some supported using the American Community Survey 6 questions on disability; some suggested that the categories were not complete or fully appropriate. There was mixed feedback on the broad functional categories and the disability populations to be included.

2.  NCQA will remove the 15-and-older age restriction to capture pediatric populations with disabilities.

3.  NCQA will not move forward with the release of the disability type categories for MY 2026. NCQA will consider public comment feedback regarding additional disability types to include and align with the most current disability standards as they become available in the field.

DECISION:
Add the DDM measure, with Disability Status Source indicator only, for MY 2026.

·    Add G0136 Assessment Code to Screening Numerator.

·    Add Z Codes to Intervention Denominator.

1.  Most comments supported adding G0136 to the screening indicators, noting alignment with clinical workflows and expanded roles of community health workers. Some raised concerns about reimbursement, adoption in Medicaid and limited pediatric use.

2.  There was strong support for adding Z codes to the intervention denominator. Feedback was mixed on whether Z codes should also count in the screening numerator, and concerns were raised about duplicate counting.

2.  NCQA added Z codes to the intervention denominator only to maintain clarity in the screening indicators. Duplication concerns will be addressed by the measure logic when programmed.

·    Remove “Assessments” from the Intervention Numerator.

4.  Most commenters agreed with removing assessment codes from the intervention indicator, reinforcing the distinction between screenings and interventions.

5.  Many commenters emphasized concerns about provider burden, especially for small or independent practices, and called for incentives, clearer coding guidance and better alignment between payers and providers.

6.  Stakeholders noted limitations in data availability for social needs, calling for improved EHR interoperability and alignment with national data standards (e.g., United States Core Data for Interoperability).

7. Some comments recommended expanding I-SNP and long-term institutional stay (LTI) exclusions to all age groups.

4.  NCQA removed assessment codes from the intervention indicator. These codes are not specific to SDOH-related assessments. The new G0136 code is captured in screening indicators.

5.  NCQA will continue to monitor data availability and interoperability trends, adjust the measure as standards and documentation improve and provide resources to support the field.

6.  NCQA updated the current measure to include additional SDOH-related codes.

7.  NCQA will expand I-SNP and LTI exclusions to all age groups.

DECISION:
Include all proposed changes to SNS-E for MY 2026.

·    Add the COVID-19 immunization status indicator that targets adults 19 and older.

1.  Comments noted concern with the ability to overcome vaccine hesitancy, and that issues related to hesitancy make continuing conversations with patients difficult. Some comments expressed that continuing to push vaccination after patients express disinterest can erode trust between providers and patients.

2.  Several comments requested patient refusal to be included as an exclusion, noting support of the indicator if patient refusal is an exclusion.

3.  NCQA received feedback on concerns about ACIP COVID-19 vaccination guidelines. Comments noted disagreement with the evidence used to create the guidelines, believing better evidence is needed before reaching a consensus. Comments also noted guideline instability, citing numerous changes over the years. A few comments stated that the

2.  NCQA will not add patient refusal to exclusion criteria for this indicator, which is supported by experts. The goal is to encourage plans and providers to continue conversations with patients regarding COVID-19 immunization, even after refusal, as this is generally best practice with all immunizations. Further, during testing of the COVID-19 indicator, plans stated that they could not identify patient refusals in the data.

4. Several comments expressed concern with data accessibility and availability, noting that many patients receive COVID-19 vaccinations outside the medical home; because of this, many plans do not receive data on the completed vaccination. Comments also noted interoperability challenges and lack of data completeness when using immunization registries to obtain information. Comments noted that state laws may limit a plan’s ability to access state immunization registries, creating an additional barrier to reporting.

4.  NCQA recognizes the challenges of immunization registry data. They are not unique to the COVID-19 indicator, and do impact other indicators in AIS-E equally, as well as other HEDIS immunization measures. NCQA is working with stakeholders across the field to understand how we can improve interoperability. Although experts acknowledged issues with data accessibility, they support moving the measure forward.

DECISION:
Add the COVID-19 indicator for adults 65+ years to
the AIS-E measure for MY 2026.

·    Remove hybrid reporting and transition to electronic clinical data systems (ECDS) reporting.

1.  Majority support for the ECDS transition to allow better data capture and interoperability.

2.  Some concerns with transition due to lack of digital infrastructure for smaller and rural practices.

3. Additional considerations about updating the measure to align with current clinical guidance and other reporting programs.

2.  HEDIS reporting data and trends for the LSC measure indicate that there is very little contribution from medical record review data. Lead screening information is highly standardized and structured, and typically accessible to health plans for quality reporting. Transitioning to ECDS reporting will provide an opportunity to improve data links with state public health agencies.

3.  NCQA is aware of the need to align LSC with current clinical guidelines and reporting requirements for other programs, and plans to pursue updates as part of a future, broader pediatric measures refresh.

DECISION:
Remove hybrid reporting and transition LSC measure to the ECDS reporting method for MY 2026.

·    Allow substance use disorder (SUD) diagnosis in any

1.  Support for allowing SUD diagnosis in any position for numerator events.

2.  Support for adding peer support services as a follow-up option.

2.  NCQA will also move forward with adding peer support services as a follow-up option, as the proposed change received a positive response.

·    Add peer support services as a follow-up option.

·    Remove pharmacotherapy dispensing events as follow-up.

DECISION:
Include proposed changes to the FUI measure for
MY 2026, except for the removal of pharmacotherapy dispensing events as follow-up.

·    Remove sex-specific age bands.

·    Expand the upper age limit to 85.

·    Refine the definition of atherosclerotic cardiovascular disease (ASCVD).

·    Remove the exclusion for members in I-SNPs or LTI.

1.  Concerns with removing sex-specific age bands.

2.  Concerns with expanding the upper age limit to include members up to age 85.

3.  Concerns with removing the exclusion for members in
I-SNPs or LTI.

2.  Due to controversy over the strength of evidence for statin use in this older adult population, NCQA will not expand the upper age limit to 85.

3.  Removal of this exclusion aligns with guidance from expert panels, and would promote better care for individuals with ASCVD, who are currently excluded from statin therapy measures.

DECISION:
Include all proposed changes to the SPC measure for MY 2026, except for the expanded age band.

·    Refine the definition of ASCVD.

·    Remove the exclusion for members in I-SNPs or LTI.

1.  Concern with removing the exclusion for members in
I-SNPs or LTI.

DECISION:
Include all proposed changes to the SPD measure for MY 2026.

1.  AMR measure is not aligned with current guidelines and asthma treatment approaches.

2. Commenters expressed concern about the lack of an asthma medication measure if AMR is retired.

2.  NCQA is considering alternative measure concepts that assess asthma medication management or overuse.

DECISION:
Retire the AMR measure for MY 2026.

·    Add Middle Eastern or North African (MENA) as a minimum reporting category.

·    Update terminology to align with the Office of Management and Budget (OMB) Statistical Policy Directive (SPD) 15.

·    Combine race and ethnicity into a single reporting unit that allows multiple responses.

1.  Support for adding the MENA category.

2.  Concern about the timeline for proposed updates. Comments noted that the OMB directive includes a federal deadline of March 2029 for agencies to be in compliance with the directive, and that altering the timeline isn’t feasible with current workflows and EHR systems.

3.  Concerns that existing data interoperability standards are a barrier to updating systems to combine race and ethnicity without falling out of compliance with other federal data guidelines or creating a burdensome system necessitating maintaining two sets of data.

4. Request from NCQA or the federal government to provide guidance on mapping data from the previous 1997 OMB standard to the updated 2024 format to facilitate reporting and collection during the transition period.

2.  NCQA acknowledges that the transition to new standards will require time and effort. Final updates limit structural changes to adding the MENA category, and use existing data terminology to reduce the need to remap fields. Updates do not mandate a change to data collection now, but provide a path to reporting where data are available. NCQA will postpone combining race and ethnicity into a single reporting unit to a future measurement year.

3.  NCQA acknowledges the potential misalignment from implementing a combined race and ethnicity reporting unit. While this is an important step toward improving the capture of certain populations, such as multiracial or Hispanic individuals, existing data standards limit the ability to support this transition. NCQA will postpone combining race and ethnicity, and will monitor data interoperability standards to identify when changes can be implemented.

4.  NCQA recognizes the importance of systematic guidance and best practices in data collection and reporting efforts. We plan to seek further input from internal/external data experts and health plans to develop tools to help the transition to 2024 OMB SPD 15 data standards.

DECISION:
Align the HEDIS RES to SPD 15 by adding MENA as a minimum reporting category and updating terminology for MY 2026.

1.  Recommendations to include alternative lipid-lowering therapies in the measure.

2. Recommendations to align with the Statin Therapy for Patients With Diabetes and Statin Therapy for Patients With Cardiovascular Disease HEDIS measures and updates.

2.  This measure will be implemented at the clinician level. It is specific to patients with diabetes; changes to HEDIS statin measures do not apply to the DRP measure.

DECISION:
Include STP in the next release of the DRP.

1.  Requests for clarification on the measure specification, including why the measure is specific to patients with diabetes, and how it will be implemented.

2. Concerns about potential challenges to accessing behavioral health services data.

2.  The measure includes multiple numerator options that give clinicians flexibility in reporting data relevant to their practice. NCQA will continue to evaluate data access barriers during implementation of the measure.

DECISION:
Include DSD in the next release of the DRP.

1.  Concerns about health plan coverage for continuous glucose monitoring (CGM) devices and cost-sharing burden.

2.  Suggestions that the measure assess CGM wear time, length of use or adherence.

3.  Suggestions to align with evolving guidelines by including patients at high risk of hypoglycemia, adults with diabetes on any type of insulin therapy and adults with type 2 diabetes on glucose lowering medications other than insulin.

4. Concerns about potential challenges to accessing CGM data.

2.  Assessment of CGM duration and activity are beyond the scope of the measure’s intent and current data standards.

3.  NCQA’s expert and advisory panels agreed with not expanding the measure to broader populations while coding and coverage evolves.

4.  The measure looks for evidence of CGM use, but does not require complete data from CGM devices.

DECISION:
Include CGD in the next release of the DRP.