October 3, 2022
U.S. Chief Data Scientist
Office of Science and Technology Policy
Attn: NSTC Subcommittee on Equitable Data,
Office of Science and Technology Policy, Eisenhower Executive Office Building
1650 Pennsylvania Ave. NW
Washington, DC 20504
RE: Engagement and Accountability RFI
Dear Ms. Ross,
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on advancing equity through community data partnerships. 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 quality measurement. Our mission to improve the quality of health for all Americans, with an intentional focus on health equity, propels our daily work. Leveraging our strengths as a trusted third party, we are committed to helping organizations move toward a more equitable health care system through accountability, transparency and measurement.
We are pleased to provide comments on the opportunities for data to support the federal government’s efforts to identify inequitable health outcomes and establish systems for measuring health-related social needs.
#3: What policies, resources, programs, training, or other tools can facilitate increased data sharing between different levels of government (Tribal, territorial, local, State, or Federal) around equitable data?
The COVID-19 Pandemic has exacerbated our nation’s health inequities, and our ability to capture the magnitude of disparities has been hindered by incomplete or missing data. We encourage the Administration and HHS to establish policies to leverage national Accreditation standards to enhance health care organizations’ capacity to collect data to identify and address health inequities. Accreditation standards help align data collection across the health care system, including social/ community services, with a common set of consensus-driven principles.
During the pandemic, policymakers have turned to NCQA’s Health Equity Accreditation to establish requirements to close inequitable gaps in health outcomes by focusing on data collection and core quality-improvement standards. NCQA’s Health Equity Accreditation is a rebranding and update to our Multicultural Health Care Distinction program, in place for over a decade and based on the HHS Office of Minority Health’s CLAS Standards.
To date, 154 organizations have either achieved Health Equity Accreditation or have a survey scheduled. Ten states are leveraging Accreditation in their Medicaid or state-based Marketplace/ Exchange programs, and CMS is considering the benefits of Health Equity Accreditation for all Marketplace/Exchange plans in recent health equity RFIs. While the program’s historic use has been with insurers, we designed the latest update to ensure that ACOs, FQHCs and health systems/hospitals are able to work with their partners on aligned standards.
Additionally, after a successful pilot with nine leading health organizations, including two health systems, this month we launched Health Equity Accreditation Plus. This program emphasizes the role of community and cross-sector partnerships in improving and addressing health-related social needs, and includes standards for data collection, data sharing and building and strengthening cross-sector partnerships.
Important to note, Health Equity Accreditation and Health Equity Accreditation Plus purposefully align with existing industry efforts, like the Gravity Project, and with federal efforts, like USCDI, to standardize data for a more equitable American health care system. Accreditation provides an additional level of adoption and oversight that is not built into existing federal programs.
#6: What policies, resources, programs, training, or tools can make equitable data more accessible and useable for members of the public.
Advancing equity requires an appropriate level of data that can be disaggregated by demographic, geographic and other variables to enable insights on health disparities. For over 30 years, HEDIS® has been one of health care’s most widely used performance improvement tools—over 200 million people are enrolled in health plans that report HEDIS results. States and the federal government use HEDIS for public transparency and accountability of contracted health plan and provider partners.
Better transparency of performance by race and ethnicity will illuminate and aid investigation of care gaps and inequitable care. As of August, NCQA has released 13 measures that can be stratified reliably by race and ethnicity (NCQA Updates & Releases New Quality Measures for HEDIS 2023 with a Focus on Health Equity). This effort will ensure that federal programs can benchmark and make apples-to-apples comparisons based on organizational performance for reducing unequal gaps in health outcomes.
We recently released the Social Need Screening and Intervention measure, which assesses screening for unmet food, housing and transportation needs, and includes referral to intervention after a positive screen. Because these data can be captured in a variety of electronic data sources (e.g., EMRs, resource referral platforms, case management systems), this measure is specified for Electronic Clinical Data System (ECDS) reporting. To reduce burden, state and federal agencies should evaluate available tools for aligning data collection and sharing, and the federal government should encourage alignment with national data standards. For example, NCQA supports aligning measures and data elements with the Gravity Project’s work to standardize interoperable social needs data.
We thank the Administration for its commitment to rectifying historic health inequities. Our team remains dedicated to supporting federal, state and local communities to ensure that every American has a health system that meets their cultural, language and social needs.
As the OSTP considers policies across the federal government, we invite you to visit our Health Equity Resource Hub, which contains publications relevant to your exploration, including our recent reports, Federal Action Is Needed to Improve Race and Ethnicity Data in Health Programs and Improving Data on Race and Ethnicity: A Roadmap to Measure and Advance Health Equity.
Thank you again for the opportunity to comment. We welcome the chance to discuss our experience and findings, and we look forward to working with the Biden-Harris Administration to build a more equitable, sustainable and responsible American health care system. If you have any questions, please contact Eric Musser, NCQA Assistant Vice President of Federal Affairs, at (202) 955-3590 or at firstname.lastname@example.org.
Margaret E. O’Kane