Although HEDIS/CAHPS results collected in 2020 reflect Measurement Year (MY) 2019, COVID-19 is impacting key aspects of HEDIS hybrid data collection and consumer experience nationally in 2020. The NCQA ratings methodology includes HEDIS/CAHPS measures and Accreditation status. While HEDIS/CAHPS reporting remains a required component of commercial and Medicaid Accreditation, we will not calculate an overall Health Plan Rating for MY 2019, because key aspects of data collection—especially consumer experience/CAHPS survey data—are understood to be compromised by the 2020 pandemic.
In addition to Accreditation, there are two components of Health Plan Ratings to consider when determining comparability for performance assessment: HEDIS and CAHPS results.
- Measures specified to use administrative data only: We expect HEDIS administrative measures to be less impacted; however, we are monitoring them closely.
- Measures specified to use administrative data with a medical record review component (Hybrid Method): We expect some HEDIS hybrid measures to be compromised, given the challenge of accessing charts for abstraction.
- CAHPS: We have concerns about the validity of CAHPS results because the survey is being fielded this year from February–May, during the height of the pandemic as it continues to spread unevenly across the country, with wide regional variation.
Considerations: Preliminary impact modeling using MY 2018 data has shown that approximately half of all plans’ overall ratings would be affected if Hybrid measures and/or CAHPS survey results were excluded from Health Plan Ratings. Given the uncertainty and likely variability of COVID-19’s impact on hybrid data collection efforts and consumer experience, NCQA will not calculate ratings for comparison of plans in 2020 for MY 2019. Ratings based on a reduced set of measures would not be comparable to previous Health Plan Ratings.
In addition, since NCQA will align with CMS guidance (https://www.federalregister.gov/documents/2020/04/06/2020-06990/medicare-and-medicaid-programs-policy-and-regulatory-revisions-in-response-to-the-covid-19-public), we will not require Medicare Advantage plans to submit data for Accreditation. In order to maintain alignment across all product lines, we want to recognize commercial and Medicaid plans for collecting and reporting data; however, we understand that some plans’ ability to submit HEDIS/CAHPS data might be compromised. We will work with these plans individually.