If information is available to the public–even if it is only available by request–NCQA considers this to be public reporting. Therefore, in this scenario the taking action date is December 1.
PHQ 2013
FAQ Directory: Physician and Hospital Quality Certification
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11.15.2012 Working with Physicians Our organization posts the results of our physician measurement program on our directory on January 1 and any tiered networks or differential benefits are effective that same date. We make the results available to members by request (e.g. the member can call an 800 number to ask about a physicians status in the tiered network) on December 1. Which date _ January 1 or December 1 _ does NCQA consider the action date for the purposes of calculating whether we notify physicians 45 days ahead of action and resolve requests for corrections or changes before taking action?
11.15.2012 HEDIS measures If we use HEDIS measures, will NCQA still look at code?
No. NCQA does not evaluate an organizations code; it reviews the organizations measure specifications and compares them to the original source specification (if applicable). Note that to be considered from a standardized source, the measure must be the version specified for the level measured; e.g. HEDIS physician level measures, not plan level measures.
PHQ 2013
11.15.2012 Reapplying for certification When may an organization that fails to be certified reapply?
11.15.2012 Standardized Measure Specifications For Element A, if the organizations correction process allows elimination of non-compliant patients from the measure result at the request of the physician, even when those patients are in the standardized measure specification, is the measure still considered to be standardized?
11.15.2012 Definition of a Program How does NCQA define a program?
The definition of a program is clearly defined in Section 1 of the Policies and Procedures. A physician measurement program includes: 1) A defined group of physicians– the definition must include both physician type (e.g. specialty) and geographic area covered; 2) A defined set of clinical quality, service or patient experience measures– the program may also include a defined set of cost, resource use or utilization measures; 3) A defined methodology for producing measure results; 4) A specific action taken at a specific point in time based on the measure results.
A hospital transparency program includes: 1) A defined group of hospitals– the definition must include both hospital type and location; 2) A defined set of all-payer quality or cost measures whose results are publicly reported at a specific point in time.
Distinct programs are reviewed separately and a certification decision is issued for each. Physician measurement programs and hospital transparency programs are always distinct programs, even when operated by the same legal entity. NCQA reserves the right to determine that programs that are managed in a decentralized manner constitute distinct programs for review.
To the extent that one program is a derivative of another and share common aspects (e.g., an organization uses the same measures and methodology for a single defined physician group but takes two actions [reporting and network tiering]) and the organization seeks verification for both at the same time, NCQA can review common aspects once to streamline the survey process, although these are distinct programs.
PHQ 2013
11.15.2012 Timing for Program Input In the Element B explanation under the head Feedback Timeframe requires the organization to seek feedback annually and Element C _ Program Impact requires the organization annually asses the program. Does the organization have to carry out these activities annually if its measurement cycle is every two years?
11.15.2012 Cost, resource use or utilization measures Are there standardized measures for cost, resource use or utilization? If there are none, what measures are plans using?
11.15.2012 Differentiating Between Programs If an organization measures and takes action on both primary care and for specialty care practitioners where the methodology and actions are the same but the measures vary by specialty, is this one or more program?
In general, if an organization has a measure set in which a subset of the measures apply only to some specialties (broadly including primary care as a specialty), where the methodology and actions are the same (e.g. public reporting in the same manner regardless of specialty), NCQA treats that as one program. However, if there is more than one action (e.g. public reporting, P4P), we may count them as two programs (a public reporting program and P4P program).
PHQ 2013
11.15.2012 Publically Reporting Performance-Based Payments Element A. requires that the organization must publicly report information on the percentage of total payments based on performance. Does this require that the information be published or is it acceptable to make it available and notify customers that it is available?
For Element F, the organization must demonstrate that it has a process to verify that it has followed the specifications outlined in Element C (e.g., sample sizes, attribution, statistical validity). If the organization uses a vendor to administer the survey, this process may be performed by the vendor, but documentation demonstrating how the element is met must be included for the PHQ Survey.
PHQ 2013
11.15.2012 Frequency of re-measurement For plans using patient experience measures, must re-measurement occur every two years to meet Element E?
11.15.2012 Attribution Do the NQF or HEDIS provider-level measurement specifications define attribution? For example, to whom to attribute performance: the diagnosing MD, prescribing MD, provider with most encounters and so on? If not, does this not result in variation?
Neither NQF nor HEDIS provider-level measures specifications require a specific attribution method, although HEDIS measures provide options for an organization to consider. While this might result in variation from one organization to another, there is currently no single industry standard method for attribution.
PHQ 2013
11.15.2012 Pricing for Derivative Programs How does NCQA determine which pricing tier it places a derivative product in?
NCQA prices a program and any programs it qualifies as derivative programs using the pricing tier that includes the total number of physicians measured in all the programs an organization brings forward. No individual physician is counted more than once for the purposes of determining which pricing tier is used, but the total of all physicians in all programs determines the tier used for every program.
PHQ 2013