Comment Letters
Our Public Policy team regularly submits comment letters to federal and state entities on a broad range of health care topics. Read our most recent comment letters below.
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NCQA Comments on ONC Health IT Strategic Plan
NCQA supports this plan that will foster the interoperability and data governance needed for moving to digital quality measures (dQM).
NCQA Comments on OIG’s Proposed Anti-Kickback Rule Changes
NCQA supports proposed changes to anti-kick rules for value-based payment arrangements.
NCQA Comments on Proposed Stark Rule Changes
NCQA Supports changes to the Stark rule on physician self-referral for value-based payment arrangements.
NCQA Comments on National Vaccine Plan
NCQA urges data standardization and validation and encouraging increased immunization information systems reporting
NCQA Comments on CMS Opioid Action Plan
NCQA urges support for non-opioid pain management, evidence-based treatment and expanded access to care.
NCQA Comments on External Quality Review Protocols of Managed Care Organizations
NCQA supports the addition of non-duplication language for mandatory EQR-related activities to reduce burden on managed care plans and states.
NCQA Comments on Proposed 2020 MACRA Rule
NCQA supports the move to smaller sets of specialty-specific, outcome-based and population health measures in the Merit-based Incentive Payment System (MIPS).
NCQA Comments on ACA Non-discrimination Proposal
NCQA opposed proposal to curtail protections for LGBT patients.
NCQA Comments on Patients over Paperwork
NCQA urges CMS to increase bonuses points for electronic reporting to support the move to digital quality measurement.
NCQA Comments on Proposed Rule for Inpatient and Long-term Care Hospitals
NCQA supports requiring EHR certification for electronic clinical quality measures and urges CMS to use our certification program that is the most rigorous.
NCQA Comments on ONC Data Blocking Rule
NCQA strongly supports ONC's proposed rule to promote electronic data exchange and stop data blocking, which will advance NCQA's goal of automatically extracting quality measurement data from electronic health information sources.
NCQA Comments on CMS Proposed Rule for Improving Interoperability and Patient Access
NCQA supports CMS proposed rule to stop data blocking and improve interoperability and patient access.