January 26, 2026
Chris Klomp, Deputy Administrator and Director
Department of Health and Human Services
Center for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Ave. SW
Washington, D.C. 20201
Attention: CMS-4212-P
Dear Deputy Administrator Klomp:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on the CMS Contract Year 2027 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program and Medicare Cost Plan Program.
NCQA is a private, 501(c)(3) nonprofit, independent organization dedicated to improving healthcare quality through our accreditation and measurement programs. We are a national leader in quality oversight and a pioneer in quality measurement. Leveraging our strengths as a trusted third party, we are committed to helping organizations navigate the challenges associated with improving the healthcare system. Our mission to improve the quality of health for all Americans propels our daily work.
NCQA is pleased to provide the following comments on the proposals and considerations outlined for the 2027 Policy and Technical Changes to the Medicare Advantage Program proposed rule.
Streamlining the Star Ratings Measure Set
NCQA applauds CMS’s proposals to streamline and reduce the Star Ratings Measure set, focusing on measures that are outcomes-based and promote high-quality care. The Star Ratings program is an essential tool for Medicare Advantage plans to assess the quality of care delivered to beneficiaries, and we are proud that NCQA’s Healthcare Effectiveness Data and Information Set (HEDIS®) measures are represented in the Star Ratings program. We are excited to see CMS’s efforts in promoting quality measures that have the most meaningful impact on improving health outcomes and are eager to continue working with CMS on our shared goal of streamlining quality measure sets.
NCQA is pleased that our Depression Screening and Follow-up Measure (DSF) is the only proposed measure to be added to the Star Ratings program. This measure is vital to assessing and ensuring beneficiaries receive necessary mental health treatment. NCQA agrees with CMS on the importance of this measure in addressing the behavioral health crisis facing Americans and supports its alignment with the Universal Foundation.
Improving Special Needs Plan Monitoring and Oversight
NCQA is enthusiastic about CMS’s interest in strengthening oversight and improving care quality for Medicare Special Needs Plans (SNPs). As the CMS‑designated accreditor, NCQA reviews every plan’s Model of Care (MOC), evaluates both clinical and non‑clinical components, assigns approval periods based on scores and maintains the national MOC scoring portal. We also provide training, technical assistance and guidance to support consistent, high-quality implementation across SNPs.
As CMS notes in the RFI, the rapid growth of dually eligible enrollment in C‑SNPs and I‑SNPs underscores the need for Medicaid coordination standards comparable to those applied to D‑SNPs, particularly where these plans function as primary coverage for beneficiaries with significant clinical and social complexity. NCQA encourages CMS to address this trend by requiring State Medicaid Agency Contracts (SMACs) for C‑SNPs and I‑SNPs. Extending SMAC requirements would help states and CMS oversee these plans more effectively, promote better alignment between Medicare and Medicaid services and ensure that beneficiaries receive coordinated care consistent with CMS’s goals.
In 2025, NCQA released D‑SNP benchmarks and trended plan‑level data, giving CMS and states enhanced visibility into variation in performance across plans serving dually eligible beneficiaries. These new HEDIS insights can support SMAC development, inform evaluation of care‑coordination performance, and identify areas where D‑SNP expectations are producing measurable improvements. NCQA welcomes the opportunity to extend these insights to C‑SNPs and I‑SNPs as CMS explores SMAC alignment across all SNP types.
Measures to Assess Well-Being and Nutrition
NCQA commends CMS for expressing interest in advancing well-being and we agree that a comprehensive, person-centered approach is vital for improving lasting health outcomes. This aligns directly with our continuous adaptation and development of HEDIS measures. By expanding measures that assess nutrition, physical activity and sleep health, we aim to provide Medicare Advantage plans with the necessary tools to promote proactive, personalized care. Implementing these measures reinforces incentives for plans to invest in the long-term wellness of beneficiaries by leveraging technologies that capture and track individual patient-generated data.
NCQA also appreciates CMS’s emphasis on nutrition as a foundation for preventive care. Our collaborations with specialty societies aim to align measures for obesity management and cardio-kidney-metabolic (CKM) syndrome screening to identify risks early and guide interventions that prevent long-term harm. From a patient-centered perspective, NCQA’s Patient-Centered Outcome HEDIS digital measure explores spiritual, financial, environmental and occupational wellness constructs that can influence the quality of interventions. These measures will support early risk identification and inform targeted interventions for preventable health conditions and ultimately improve Americans’ health outcomes.
RFI on the “Future Direction of MA”
NCQA recommends that CMS use CMMI’s authority to test a Medicare Advantage model centered on advancing interoperable, FHIR® API-based digital quality reporting. A demonstration of this kind would allow CMS to evaluate whether a modern, standards-based data infrastructure can accelerate the availability of high-quality, actionable performance data and reduce the time gap between care delivery and when quality results can inform payment and improvement. By requiring participating plans and delegated entities to use FHIR APIs as the foundation for quality data exchange, CMS could determine whether automated and machine-readable digital feeds provide more timely, complete, and clinically useful information that supports real-time care improvement. This approach also supports the national transition toward digital quality measurement by expanding the use of FHIR-native measure specifications and Clinical Quality Language (CQL) based logic that can be executed consistently across clinical systems.
NCQA recommends that the demonstration test how FHIR API-based reporting can reduce administrative burden and strengthen data reliability by using standardized value sets, code packages and validation tools that ensure consistent and reproducible measure calculations. Submitting quality data through FHIR APIs, including Bulk FHIR for population-level reporting, would allow CMS to examine whether seamless data exchange eliminates redundant manual processes and elevates data quality, making quality information more useful and actionable. This model would help CMS determine if more timely and accurate data can drive earlier identification of care gaps, more reliable performance assessment, and faster uptake of high-performing clinical practices.
NCQA also recommends evaluating how digital measurement can be aligned with clinical documentation workflows so that the structured data used in routine care flows naturally into quality reporting. FHIR-based reporting reduces the need for duplicative documentation and separate abstraction activities because the same data captured in the electronic health record can support both care delivery and quality measurement. Testing this alignment through a CMMI demonstration would help CMS assess how workflow-integrated digital reporting improves accuracy, reduces administrative complexity, and enables clinicians and plans to act on data more quickly. A unified digital ecosystem focused on FHIR APIs would also support faster measure development and enhanced responsiveness to emerging quality priorities.
NCQA recommends incorporating expectations for data timeliness within the model so CMS can fully evaluate the advantages of FHIR API-based reporting. More predictable digital submissions, including monthly attribution updates and complete monthly FHIR-based clinical and administrative data files, would allow CMS to assess whether more current year information can support payment methodologies that reflect recent performance rather than historical results. The model should also explore how a consistent digital measurement foundation can support alignment across Medicare Advantage, Accountable Care Organizations, the Merit-based Incentive Payment System, and the CMS Universal Foundation by anchoring all measurement in a common digital core and prioritizing provider impactable measures.
To support broad participation, NCQA recommends that CMS include targeted infrastructure and technical assistance for providers serving rural, frontier and geographically diverse communities, which often face distinct challenges related to technology capacity, workforce shortages, vendor availability and broadband connectivity. Investments in shared tooling, validated FHIR measure engines, implementation guides, technical assistance and support from certified intermediaries would help these organizations successfully adopt FHIR API-based reporting. By modernizing the data infrastructure for quality measurement and evaluating its impact across a diverse range of provider environments, CMS can determine whether a digital-first approach produces faster, more actionable quality data, reduces administrative burden, and helps Medicare Advantage plans and providers drive timely improvements in care delivery.
Thank you for the opportunity to comment. We remain committed to working with CMS to build a more efficient and responsible American healthcare system. We welcome a discussion about our experience and recommendations to further strengthen the partnership between CMS and NCQA. If you have any questions, please contact Eric Musser, Vice President of Federal Affairs, at (202) 955-3590 or at musser@ncqa.org.
Sincerely,
Dr. Vivek Garg
President & CEO