COVID-19 Regulatory Updates that Impact Health Plan CAHPS Surveys

By Esther Turner, Principal, Product Management, SPH Analytics
Twitter: @SPHAnalytics

Here at SPH Analytics we’ve been busy interpreting and addressing all of the fast and furious regulatory updates that have come from NCQA and CMS these past few days. We’ve compiled the ones that impact health plan CAHPS® surveys here for your reference. We’ll update this page as more information becomes available.

HEDIS® CAHPS (Commercial and Medicaid)
NCQA released guidance about the HEDIS CAHPS program on March 27. While NCQA is not extending the data submission deadline of May 29, 2020, they are allowing for modifications to the protocol:

  • If health plans have a mixed mode protocol (as most do) they are being allowed to move to a mail only protocol. NCQA is allowing a two-wave mail protocol.
  • One of our recommendations to NCQA was to allow a modification to the introduction of the telephone scripts. NCQA approved adding this language:

At (HEALTH PLAN) your health and safety are a priority. Amid the ongoing coronavirus pandemic, [HEALTH PLAN] continues to be committed to seeking ways to improve the services we provide to our members. For the purpose of this study, please reflect on your experience with the plan in the last (12 months/6 months).

  • NCQA approves the use of fewer than the minimum of three telephone attempts.
  • NCQA clarified that they do not permit home-based telephone interviewing at this time.

On Thursday, April 2 NCQA released additional guidance regarding scoring for Health Plan Ratings, with clarification released on April 3. While NCQA continues to require submission of HEDIS and CAHPS data for Commercial and Medicaid plans, they are not planning to score plans using Health Plan Ratings in 2020.

  • The September 2020 Health Plan Report Card update will list all plans with Interim, Accredited or Provisional status, as applicable, based on existing status or standards performance for surveys on the HPA 2020 Standards.
  • There will be no Health Plan Ratings in 2020.

This closely follows similar decisions from CMS regarding the MA & PDP Star Ratings.

NCQA does note several exceptions:

  • Out of respect for the efforts focused on COVID-19, we have implemented our disaster protocols which allow for exceptions to these reporting requirements. For commercial and Medicaid plans whose ability to submit HEDIS or CAHPS data is compromised, NCQA will work with the organization to determine the appropriate accommodations.
  • State Reporting: We respect that different states may make different decisions on HEDIS and CAHPS reporting and we will abide by those decisions on a state-by-state basis.
  • In all cases, the IDSS tool will be available for internal quality improvement purposes.

While data this year will not be used for scoring or rating purposes, we strongly believe it is an extremely valuable source of information that plans can use to track member experience during these difficult times. It is even more critical that plans review and understand their data.

MA & PDP CAHPS / Star Ratings
Significant program changes were announced by CMS this week.

  • HEDIS Clinical Quality Measure Submissions Stopped CMS is eliminating HEDIS clinical quality measure submission requirements this year and requests that MA plans curtail data collection work immediately to allow plans, providers, and physician offices to focus on caring for beneficiaries. Any HEDIS data already collected can be used for QI purposes.
  • CAHPS Submissions Stopped CMS is eliminating 2020 survey data submission requirements for MA & PDP CAHPS. Data can still be used for internal quality initiatives.
  • Using Last Year’s Data for HEDIS and CAHPS Measures CMS will replace this year’s 2021 Star Rating measures based on calculations from HEDIS or CAHPS with last year’s values. There will be no changes to the cut points for these measures.
  • If CMS Can’t Calculate any 2021 Stars They will use the 2020 stars instead. This allows for 2021 Star Ratings in the event that CMS capabilities to calculate new scores are compromised due to the pandemic.
  • Next Year For the 2022 Star Ratings, CMS expects plans to submit HEDIS and CAHPS data as usual

Check out a summary blog and a nice review of current outstanding questions by Melissa Smith at Gorman Health Group for additional information.

QHP Enrollee Experience Survey / Marketplace Quality Rating System
Survey administration and data collection has continued without interruption for this program and we don’t anticipate any changes to protocol. We await guidance from CMS about the how the Quality Rating System may be impacted for 2020.

HEDIS® is a registered trademark of the National Committee for Quality Assurance (NCQA).
CAHPS® is a registered trademark of the Agency for Healthcare Research and Quality (AHRQ).

This article was originally published on SPH Analytics and is republished here with permission.