ACAP Comments to NCQA Proposed SNP Standards
January 18, 2008 Submission
Other
The Association for Community Plans supports the development of strong quality standards for SNPs. While we support the building block approach being used to develop the standards, we are concerned that the initial standards do not address the issue of integration of Medicare and Medicaid. We believe that a SNP’s ability to integrate care is what makes SNPs valuable in comparison to other MA plans.
Given that the standards were not released for comment until December and data collection forms will not be available until April, it is unreasonable and very costly to expect health plans to complete the necessary contracting and data collection for a June 30, 2008 submission of audited HEDIS data. Moreover, the health plans are not being given adequate time to make necessary systems changes to address the particulars of the standards (i.e., automated features for Element I.C. and I.F). New measures for 2009 should be publicized as soon as possible.
Throughout the standards, NCQA does not address the issue of new plans with a small enrollment and the impact of the small sample size on the applicability of that standard in terms of cost, resources and reliability of the measure. It is unclear whether exceptions will be made for the SNP process and structure measures or if the current HEDIS exceptions based on sample size will apply. This also applies to the 2009 HOS and CAHPS measures. At a minimum, consideration should be given to allowing reporting at the contract level.
It must be stressed that any comparison of HEDIS scores for SNPs and MA plans serving members with less complex medical needs would be inappropriate. In addition, HEDIS measures developed for an elderly population may be less appropriate for SNPs with a higher proportion of disabled members.
SNP 1: Case Management - Element A: Identifying Members for Case Management
The inclusion of ordered lab tests is an appropriate data source. However, the inclusion of lab results as a required data source is problematic and should be reconsidered.
SNP 1: Case Management - Element C: Case Management Systems
This element favors highly automated case management systems. However, automation does not guarantee the development of an integrated care plan. Shouldn’t a well-developed, highly integrated care plan that recognizes and appropriately addresses the existence of co-morbid conditions be eligible for a higher score, even if the development was more manually intensive?
SNP 2: Improving Member Satisfaction - Element A: Assessing Member Satisfaction
The standard does not address the issue of new plans with a small enrollment and the impact of the small sample size on the applicability of that standard in terms of cost, resources and reliability of the measure.
SNP 2: Improving Member Satisfaction - Element B: Opportunities for Improvement
The standard does not address the issue of new plans with a small enrollment and the impact of the small sample size on the applicability of that standard in terms of cost, resources and reliability of the measure.
ACAP Comments to NCQA Proposed SNP Standards
January 18, 2008 Submission
Other
The Association for Community Plans supports the development of strong quality standards for SNPs. While we support the building block approach being used to develop the standards, we are concerned that the initial standards do not address the issue of integration of Medicare and Medicaid. We believe that a SNP’s ability to integrate care is what makes SNPs valuable in comparison to other MA plans.
Given that the standards were not released for comment until December and data collection forms will not be available until April, it is unreasonable and very costly to expect health plans to complete the necessary contracting and data collection for a June 30, 2008 submission of audited HEDIS data. Moreover, the health plans are not being given adequate time to make necessary systems changes to address the particulars of the standards (i.e., automated features for Element I.C. and I.F). New measures for 2009 should be publicized as soon as possible.
Throughout the standards, NCQA does not address the issue of new plans with a small enrollment and the impact of the small sample size on the applicability of that standard in terms of cost, resources and reliability of the measure. It is unclear whether exceptions will be made for the SNP process and structure measures or if the current HEDIS exceptions based on sample size will apply. This also applies to the 2009 HOS and CAHPS measures. At a minimum, consideration should be given to allowing reporting at the contract level.
It must be stressed that any comparison of HEDIS scores for SNPs and MA plans serving members with less complex medical needs would be inappropriate. In addition, HEDIS measures developed for an elderly population may be less appropriate for SNPs with a higher proportion of disabled members.
SNP 1: Case Management - Element A: Identifying Members for Case Management
The inclusion of ordered lab tests is an appropriate data source. However, the inclusion of lab results as a required data source is problematic and should be reconsidered.
SNP 1: Case Management - Element C: Case Management Systems
This element favors highly automated case management systems. However, automation does not guarantee the development of an integrated care plan. Shouldn’t a well-developed, highly integrated care plan that recognizes and appropriately addresses the existence of co-morbid conditions be eligible for a higher score, even if the development was more manually intensive?
SNP 2: Improving Member Satisfaction - Element A: Assessing Member Satisfaction
The standard does not address the issue of new plans with a small enrollment and the impact of the small sample size on the applicability of that standard in terms of cost, resources and reliability of the measure.
SNP 2: Improving Member Satisfaction - Element B: Opportunities for Improvement
The standard does not address the issue of new plans with a small enrollment and the impact of the small sample size on the applicability of that standard in terms of cost, resources and reliability of the measure.