August 1, 2022
Admiral Rachel L. Levine, MD
Assistant Secretary for Health
U.S. Department of Health and Human Services
200 Independence Avenue SW
Washington, DC 20201
Dear Admiral Levine:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to comment on the HHS OASH RFI to strengthen primary care.
NCQA is a private, 501(c)(3) not-for-profit, independent organization dedicated to improving health care quality through our Accreditation and measurement programs. We are 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 associated with addressing population health needs. Our mission to improve the quality of health for all Americans, with an intentional focus on health equity, propels our daily work.
NCQA is pleased to provide the following comments to guide HHS OASH efforts in strengthening primary care across the nation.
Successful Models and Innovations for Primary Care
To further support improved primary care outcomes, NCQA developed a Patient Centered Medical Home (PCMH) Recognition program to provide a foundational model for health care organizations to transform primary care. NCQA’s PCMH Recognition program is the most widely adopted medical home model for primary care in the country and works to improve patient experience, staff satisfaction and health care efficiency all while reducing costs.1 More than 10,000 practices (with 50,000+ clinicians) are recognized by NCQA and over 95 organizations support NCQA Recognition through providing financial incentives, transformation support, care management, or learning collaboratives.1
NCQA PCMH models support primary care improvement by focusing on electronic health record optimization, analytics, population health management, and community and network integration.2 Use of these models puts parameters in place for team-based care, coordination with public health, and staffing/care delivery structures to enhance chronic disease management and disease prevention. Patients treated in PCMHs tend to receive preventative services and screenings at a higher rate than patients not in PCMHs and experience better communication with their clinical teams.3 The PCMH model also provides significant benefits for clinicians including earning higher reimbursement and succeeding in Medicare Access and CHIP Reauthorization Act (MACRA). Over 100 payers and organizations offer enhanced reimbursements for PCMH recognized clinicians and the Centers for Medicare and Medicaid Services (CMS) acknowledges NCQA’s PCMH program as a way for clinicians to receive MACRA credit.3
NCQA PCMH recognition closely aligns the goals of primary care with the goals of public health and has been shown to support primary care improvement by reducing emergency department utilization and disparities in care.2 As of July 2022, 25 states have implemented PCMH programs and incentivized their programs through Value-Based Payment models, financial incentives, or oversight relief. All 25 state programs recognize NCQA-specific PCMH recognition and 10 require NCQA PCMH recognition. Additionally, D.C., Iowa, and Mississippi mandate PCMH recognition to serve specific Medicaid populations.
Barriers to Implementing Successful Models or Innovations
The three main barriers to practices becoming PCMH recognized is lack of staff bandwidth, lack of incentives for maintaining recognition, and limited resources to dedicate to transforming into a PCMH. However, states are taking action against these barriers and creating their own solutions. The New York State PCMH model is an example of state government incentivizing and aiding practices in becoming a PCMH which resulted in improved primary care throughout the state.
Additionally, public healthcare programs should look toward the fee schedule and rate-setting process for embedding PCMH expectations and the corresponding costs associated with development and implementation. PCMH expectations and incentives should not occur in a silo outside of the routine reimbursement process but should be integrated for more streamlined PCMH operations. Below, we provide recommendations on how to address the barriers associated with successful PCMH model implementation.
Proposed HHS Actions
NCQA recommends CMS consider policies and financing mechanisms in public programs that modify the rate-setting and fee schedule process for primary care physicians to reflect the implementation and ongoing operations of a PCMH model, thereby institutionalizing the model rather than continuing to make it optional. With robust evidence now available supporting the value of PCMH practices, we believe CMS should establish the PCMH model of care as the universal standard of care in the US healthcare system by enabling purchasers, providers, and payers to address these resource barriers through existing financing mechanisms.
NCQA also recommends HHS invest in and enable care for complex needs by integrating access to social services and primary health care through partnerships. However, in order to deliver on this, key population-level information across multiple settings of care must be integrated and accessible to primary care. NCQA commends HHS for prioritizing primary care and we welcome the opportunity to discuss our recommendations.
Thank you again for the opportunity to comment. We remain committed to improving health outcomes and building a stronger primary care system for all Americans. If you have any questions, please contact Olivia Umoren, NCQA Federal Affairs Manager, at (202) 827-9450 or at oumoren@ncqa.org.
Sincerely,
Margaret E. O’Kane
President
1NCQA. Patient Centered Medical Home (PCMH) Recognition Program. https://www.ncqa.org/programs/health-care-providers-practices/patient-centered-medical-home-pcmh/
2Philip, S., Govier, D., & Pantely, S. (June 2019) Patient-Centered Medical Home: Developing the Business Case from a Practice Perspective. https://www.ncqa.org/wp-content/uploads/2019/06/06142019_WhitePaper_Milliman_BusinessCasePCMH.pdf
3NCQA. PCMH Benefits to Practices, Clinicians and Patients. https://www.ncqa.org/programs/health-care-providers-practices/patient-centered-medical-home-pcmh/benefits-support/benefits/