April 19, 2022
Agency for Healthcare Research and Quality (AHRQ)
5600 Fishers Lane, 7th Floor
Rockville, MD 20857
Dear Dr. Karen Rhodes:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to respond to the request for stakeholder feedback on the proposed strategic framework for AHRQ’s Patient-Centered Outcomes Research Trust Fund (PCORTF) investments.
NCQA is a private, 501(c)(3) not-for-profit organization dedicated to improving health care quality through our Accreditation and measurement programs. As an independent organization dedicated to improving health care quality through measurement, transparency, and accountability, NCQA is a national leader in quality oversight and a pioneer in digital quality measurement. Leveraging our strengths as a trusted third party, we are committed to helping organizations navigate the challenges of transitioning to a digital future; and we consistently look to the evidence AHRQ produces to ensure our programs and measures disseminate the best practices of patient-centered outcomes research.
NCQA is pleased to provide the following comments on the strategic framework to guide AHRQ’s PCORTF investments.
Feedback on the framework overall
We strongly support AHRQ’s mission, vision, and goals of the overall framework and we applaud the agency’s focus on engaging underrepresented communities and historically marginalized individuals. We are encouraged to see a priority and desired outcome is to co-design innovations in care with patients and communities. We believe this theme could be implemented more broadly throughout the framework.
In addition, there should be a sharper focus on leveraging new digital technologies to make the collection and use of patient-centered data and interventions more feasible and sustainable. We suggest adding “digitally enabled” to the high-level goal of the framework: to improve health outcomes by promoting high-value, safe, evidence-based, integrated, digitally enabled, coordinated, team-based, patient-centered care, with a focus on underserved populations.
Finally, since the goal of this framework is to drive dissemination and sustainable implementation of PCOR, AHRQ should consider how broader contextual factors affect implementation. These contextual factors include things like payment arrangements and incentives as well as existing community resources and relationships. AHRQ’s work on context in previous programs offers lessons about these barriers and facilitators.
High-level priority areas
We believe it’s appropriate to make health equity the first high-level priority and is consistent with President Biden’s EO 13985 on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government.
Additionally, we think AHRQ is well positioned to help the nation assess the potential opportunity and impact of technology, or digital tools, in exacerbating or ameliorating health care disparities. We believe the health equity high-level priority should include ensuring digital technologies are co-designed with diverse stakeholders with different lived experience. As new digital technologies proliferate through government funding, we must ensure we address the digital divide and create equitable frameworks for data governance and data sharing. NCQA is proud to support AHRQ’s initial research in this area.
Within the framework there are a few references to the Learning Health System (LHS), which can only be achieved through healthcare’s digital transformation and with a commitment to digitizing health care data to enable rapid feedback and integrated content development across clinical guidelines, decision supports, quality measures, and data specifications. While we support the concept of the LHS and believe it’s the right direction for our national health care data infrastructure, more research is needed to identify the needs and opportunities for stakeholders working within a LHS model. AHRQ seems like the right federal agency to explore the impact on patients, care teams, quality improvement specialists, and payers in the transition to a national LHS.
Targeting investments within high-priority areas
Digital technologies and tools to advance equitable outcomes need significant research investment and would bolster the output of PCORTF. AHRQ should also target investments across the continuum of care. For example, AHRQ could invest in research to examine how health care services delivered in the home prevent emergency department or hospital visits, as well as shorten hospital stays and avoid transitions into post-acute care facilities.
Prevention should remain an important area for investment, particularly as it relates to children and youth. The pandemic has created disruptions in education and access to school-based services for vulnerable children; while social isolation, family stress, and stress from community and global events have exacerbated the existing mental health crisis. Investments to mitigate long term impacts of the pandemic on health outcomes, particularly mental health outcomes, are critical.
Achieving the vision and mission of the strategic framework
To have the greatest impact and success at achieving the vision and mission of the framework, AHRQ should build on its existing strong initiatives, such as the Evidence-based Practice Center and the ACTION Network. In particular, the ACTION network offers the opportunity to address questions about real-world implementation and is already executing on one of the cross-cutting strategies of the framework to provide the evidence to inform policy change. AHRQ should prioritize investing more resources in these existing efforts and expand task orders, and potentially prioritize a smaller number of task orders.
NCQA also recommends increased partnership between AHRQ and PCORI. AHRQ could build on PCORNet resources to acquire more information about the implementation and long-term sustainability of research findings. AHRQ could also add to, and help disseminate more PCORI tools, while learning from PCORI’s experience with patient and community engagement.
Thank you again for the opportunity to comment. We remain committed to improving the nation’s health care system and we welcome a discussion on our recommendations. If you have any questions, please contact Eric Musser, NCQA Director of Federal Affairs, at (202) 955-3590 or at firstname.lastname@example.org.
Margaret E. O’Kane
 Context Matters: The Experience of 14 Research Teams in Systematically Reporting Contextual Factors Important for Practice Change
 Creating a Digital Healthcare Equity Framework With an Accompanying Guide for Its Use