CMS Suspends Quality Reporting Measures Amid Pandemic

Amid the COVID-19 pandemic, the Centers for Medicare and Medicaid Services (CMS) announced the suspension of data collection and reporting linked to several key quality programs.

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The announcement came on April 18, halting all data collection and reporting for the Qualified Health Plan Enrollee Survey, Quality Improvement Strategy, and Quality Rating System for plan year 2021. These previously mandated reporting tools capture key quality indicators of effective health plan preventive strategies, care management, and member satisfaction.

“Given the challenges healthcare providers are facing responding to the COVID-19 virus, we are not continuing with this year’s data collection and reporting efforts as that may divert physician offices from caring for patients,” the announcement said.

Each year, health plans qualifying for the federal exchange must collect clinical data on key performance metrics including Healthcare Effectiveness Data and Information Set (HEDIS) and Pharmacy Quality Alliance (PQA) measures. HEDIS and PQA help plans and providers understand if they are meeting certain benchmarks for patient wellness, like offering colonoscopies and wellness visits as well as driving medication adherence and safety.

Qualified health plans are required to report this information to CMS between May and June. But with the coronavirus outbreak, stakeholders fear reporting could risk patient care, leading to CMS suspending data collection. Provider's attention should be focused on treating patients with COVID-19 not on collecting data for quality indicators.

The move also aims to protect individuals in charge of collecting provider data. Patient medical records and information from physicians’ offices must be exchanged with payers to report on these measures. Data collectors are, therefore, at risk if they must go to a provider’s office to gather information or review patient medical records.

So CMS’ decision to suspend quality reporting allows providers to focus on patient care and keeps payers safe.

In this announcement, CMS also suspended the Qualified Health Plan Enrollee Survey, which is administered to health plan members to understand their experience with the plan. This information is communicated back to CMS and reported as a part of the plan’s rating on the Federal Health Exchange.

While many are uncertain how this will affect the federally-facilitated exchange for the 2021 open enrollment period, CMS ensured it will continue to evaluate the situation and disseminate guidelines throughout the pandemic.

All Quality Improvement Strategy data will no longer be required to submit to the 2021 federal exchange, CMS asserted. The agency is working to ensure these suspensions do not affect plan certification. Regardless, open enrollment and the federal exchange will undoubtedly look different this year as a result of the pandemic.

“We encourage states with state-based exchanges to adopt a similar approach,” the announcement recommended. So state-based exchanges will likely also have to adopt a new approach to certification if they are to mimic federal guidelines, support providers caring for patients with COVID-19, and keep payers safe.

The quality indicators are key for plan ratings, so not collecting and reporting this information will make it challenging to accurately compare plans in 2021. But the risks of reporting outweigh the rewards.

CMS encourages plans to continue capturing these quality indicators if possible for internal quality improvement programs. Plans should understand, though, that quality indicators this year might look different than in the past as many providers have shifted their focus almost entirely to COVID-19 and emergency care rather than the preventive strategies many quality indicators assess.

This will be a challenge in many value-based contracts for payers because many HEDIS, PQA, and Qualified Health Plan Enrollee Survey metrics are used as quality measures for value-based care contracting. While CMS is no longer mandating reporting, payers still need to monitor these measures if they are to report and pay out value-based care contracts to providers.

Suspending quality reporting undoubtedly relieves some burden for payers and providers, but payers will need to work closely with their providers if they are to adapt to the ever-changing environment COVID-19 has unleashed on the industry.