September 12, 2025
The Honorable Mehmet Oz
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244
Attention: CMS–1832–P
Dear Dr. Oz,
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on the CMS 2026 Physician Fee Schedule and Medicare Shared Savings Program proposed rule.
NCQA is a private, independent, 501(c)(3) not-for-profit organization committed to advancing health care quality. Through Accreditation and measurement programs, we deliver evidence-based tools that help health care organizations improve outcomes, reduce inefficiencies, and address systemic challenges. As a trusted third party and national leader in quality oversight, we enable the private sector to solve problems effectively—driving innovation, accountability, and meaningful change. Our mission to improve the quality of health for all Americans guides our daily work.
NCQA appreciates the opportunity to submit feedback regarding the proposals and considerations presented in RFIs in CMS–1832–P:
- Well-Being and Nutrition Measures.
- Prevention and Management of Chronic Disease.
- Core Elements.
- Data Quality & Digital Quality Measurement.
Well-Being and Nutrition Measures RFI
We appreciate CMS’s interest in advancing well-being and nutrition measures in CMS quality programs, and we are working on initiatives to support this vision. As part of our efforts to support prevention and management of cardio-kidney-metabolic (CKM) syndrome and related chronic conditions, we are adapting existing HEDIS® measures and developing new measures—designed for use by health plans, care delivery organizations and health technology vendors—that focus on quality of care for nutrition, physical activity and sleep. Measures leverage technologies that capture and track patient-generated data to support more personalized, proactive care.
NCQA has also developed a digital HEDIS measure to address non-medical barriers to wellness attainment, such as food insecurity (including access to nutritious foods), transportation access and housing stability. And we are exploring new methods to assess care quality for beneficiaries with limited access to healthy food, parks, playgrounds and public spaces that promote physical activity and community engagement. Our intent is to provide information to plans, members and providers that allows them to target health improvement efforts toward beneficiaries at greater risk of poor health outcomes.
NCQA is working closely with specialty societies to align new measures of obesity management, including screening for CKM syndrome, so early risk can be mitigated to prevent long term harm. These measures will help assess risk and guide interventions for preventable health problems, and contribute to long-term wellness outcomes.
In the behavioral health domain, NCQA is working with the industry and provider organizations to implement and refine digital measures for care of mood and substance use disorders, emphasizing recognition, treatment and improvement—key components of emotional well-being.
Beyond clinical measures, NCQA has a track record of developing and implementing measures to support effective business partnerships to address wellness at the population level. Our Wellness and Health Promotion Accreditation/Certification includes metrics focused on keeping populations healthy (e.g., completion of health appraisals, success in keeping healthy populations healthy) and wellness program outcomes (e.g., success in reducing risks related to BMI, smoking/tobacco use and physical activity).
NCQA is also focused on putting patients at the center of quality, building on the Patient-Centered Outcome HEDIS digital measure to explore concepts related to functional attainment, including spiritual, financial, social, environmental and occupational wellness—constructs that can guide the quality of interventions. For pediatric and adolescent populations, we are optimizing existing HEDIS wellness measures across these domains to promote early engagement in health and well-being.
Prevention and Management of Chronic Disease RFI
NCQA commends CMS for its leadership in advancing prevention and wellness through innovative care models and evidence-based strategies. NCQA is developing a program to define and evaluate high-quality digital health and condition management solutions. Digital health tools—often asynchronous, app-based and patient-directed—offer new opportunities for engagement, but the current ecosystem lacks consistent standards for assessing their clinical rigor, usability and data exchange capabilities. These applications also provide expanded access to patient-generated data that can be used for more robust risk stratification to allow for targeted, efficient, intervention. NCQA’s program will establish consistent expectations for digital health products by standardizing engagement metrics and outcomes, enabling purchasers to evaluate their impact on member health, set quality targets and build confidence in their value. We encourage CMS to anchor digital health innovation in trusted, independent evaluation to accelerate adoption, reduce risk and ensure meaningful value for patients and the health care system.
To support development of this program, NCQA is convening a multi-stakeholder working group that includes providers, health systems, digital health vendors, payers, patient advocates, policymakers and employers. The group will begin meeting in September, with ongoing engagement anticipated. Discussions will focus on best practices for delivering wellness, health promotion and condition management services; improving patient engagement and outcomes; demonstrating return on investment; and exploring whether wellness and condition management should be treated as distinct or unified strategies. Participants will share insights into their approaches to digital patient engagement and person-centered care. All information shared will inform updates to programs such as NCQA’s longstanding Wellness and Health Promotion Accreditation/Certification, and will guide development of new initiatives that reflect industry needs.
NCQA supports CMS’s interest in expanding services that address social isolation, physical activity and self-management of chronic disease. We recommend recognizing motivational interviewing and health coaching as reimbursable services; supporting FDA-cleared digital therapeutics and medically tailored meals under general supervision; and facilitating partnerships among providers, public health institutions and community-based organizations. NCQA’s Wellness and Health Promotion Accreditation/Certification program evaluates how organizations engage individuals (through self-management tools and health coaching) in healthy behaviors, including nutrition and physical activity. CMS could leverage this program to assess and compare the quality of health care organizations’ wellness and health promotion initiatives, empowering consumers to make informed choices about their health. We also encourage CMS to explore digital-first approaches to nutrition, physical activity and sleep measurement that enable direct patient input and support real-time tracking of behaviors and interventions.
Core Elements RFI
NCQA commends CMS for its continued efforts to improve the relevance, comparability and usability of clinician performance data through the MIPS Value Pathways (MVP). We strongly support the introduction of Core Elements as a strategic mechanism to standardize performance measurement across clinicians within the same MVP. Elements should reflect evidence-based, person-centered care, and should align with the Universal Foundation—70% of which are NCQA HEDIS measures. Alignment ensures that measures are meaningful across specialties and care settings, and that they support outcomes that matter to patients.
CMS’s Core Elements initiative aligns with NCQA’s digital measurement strategy, which emphasizes development of a shared infrastructure for quality measurement across health care settings, and prioritizes measures that reflect outcomes, experience, access, coordination and safety. We welcome continued collaboration with CMS on measure development, validation and implementation strategies, and we encourage CMS to expand technical assistance and learning collaboratives to prepare providers and health systems for the transition to digital quality measurement.
Data Quality & Digital Quality Measurement in CMS Quality Programs RFIs
NCQA appreciates the opportunity to respond to CMS’s RFIs on Data Quality and Digital Quality Measurement. We strongly support CMS’s efforts to modernize quality measurement and improve the reliability, usability and interoperability of health data across programs and care settings. Central to this transformation is the need for standardized data infrastructure and computable measure logic that can be consistently applied across platforms, providers and programs.
At the heart of NCQA’s digital measurement strategy is the use of Clinical Quality Language (CQL) and standardized data quality rules to help ensure that digital measures are not only executable, but also meaningful. CQL enables automated quality measurement and clinical decision support by allowing systems to interpret and apply measure logic directly to patient data. This capability is foundational for value-based care, where timely, accurate, standardized data are essential for evaluating performance and improving outcomes. NCQA uses CQL to make the logic behind each HEDIS measure transparent, testable and aligned with national standards. CMS’s prioritization of the shift from QRDA to FHIR-based CQL measures reinforces the importance of this capability across the health care ecosystem.
Executing measure logic is only part of the equation, however. NCQA’s experience implementing digital HEDIS measures through our Digital Content Services has shown that data quality and readiness are the true determinants of success. In practice, EHR and HIE feeds may meet federal interoperability standards, yet deliver unusable data due to reliance on proprietary or non-standard value sets. In one large-scale implementation, nearly 50% of inbound data proved not fit for use, despite appearing compliant at first glance. This underscores the need for solutions that go beyond ingestion to include rigorous data quality checks and normalization against standards to make data truly fit for use.
In response, NCQA is developing a data quality offering that combines digital data quality rules with a certification model. Rules evaluate conformance, plausibility, completeness and provenance, and are designed to be compatible with HL7 standards. NCQA will certify implementation of this content and data aggregator practices, providing a scalable way to validate that data are reliable for reporting and quality programs. Our Data Aggregator Validation program has already become a national best practice for establishing trust in upstream data used for HEDIS reporting. While rigorous, it includes manual elements, like primary source verification, that make it time-intensive. We recognize the need for approaches that are better integrated into workflows and a lighter lift for organizations while maintaining the same level of trust and rigor.
To simplify clinical quality data responsibilities for providers, NCQA urges CMS to accelerate the transition to digital quality measurement using standardized, computable measures aligned with HL7 FHIR. Measures should be fully specified to reduce interpretation and coding burden, configurable for multiple use cases and interoperable across programs and EHR vendors. This would allow providers to report once and use the data across multiple programs, reducing redundancy and administrative burden.
NCQA is also piloting delivery models to support scalable data quality validation that allows third-party developers (e.g., HIEs, care delivery or analytics platforms) to implement NCQA-defined data quality evaluation content and earn certification.
NCQA stands ready to collaborate with CMS, states and other measure developers to support alignment, implementation and broader adoption of digital quality measurement and data quality standards across the health care ecosystem.
Thank you for the opportunity to comment. We remain committed to working with CMS to build a more efficient and responsible American health care system. We welcome a discussion on our experience and our recommendations to continue to strengthen the Medicare program. If you have any questions, please contact Eric Musser, Vice President of Federal Affairs, at (202) 955-3590 or at musser@ncqa.org.
Sincerely,
Margaret E. O’Kane
President
National Committee for Quality Assurance