Preparing for a “Universal Foundation” of quality measures

Change is on the horizon for health plan quality measurement and reporting as the Centers for Medicare & Medicaid Services (CMS) looks to standardize measures across numerous programs. In summer 2022, the agency first proposed the use of consistent, nationally standardized quality core measures in Medicaid and the Children’s Health Insurance Program (CHIP).

The Core Sets are designed to measure the quality of care for beneficiaries on a national scale, monitor performance at the state level, and improve the overall quality of healthcare. They include a range of measures to evaluate how Medicaid and CHIP coverage is meeting the needs of individuals and their communities, determine whether there are health disparities, and identify how the quality of care can be improved.

“The Medicaid and CHIP Core Sets of quality measures for children, adults, and health home services are key to promoting health equity. They will allow us not only to identify health disparities but also to implement interventions based on the very data that make those disparities clear.” — Chiquita Brooks-LaSure, CMS Administrator

CMS is currently asking for voluntary reporting for the new measures, but reporting becomes mandatory in 2024. Its aim is to reduce provider and plan burden by streamlining processes, aligning resources, allowing providers to focus their attention on standards that are meaningful across populations, advancing equity, and aiding in reporting.

Universal Foundation quality measures

In addition to the 2022 standardization measures, CMS asked for comments on its “Universal Foundation” quality measures in the 2024 Medicare Advantage and Part D Advance Notice. This would create a standard baseline across all CMS quality programs for adult and pediatric populations and ease the burden of having a multitude of different reporting requirements.

CMS says the Universal Foundation quality measures are crucial to promoting health equity. The measures selected are meant to address many of the health problems associated with things such as morbidity and mortality for both children (Figure 1) and adults (Figure 2) in the United States. The measures selected will help CMS recognize, track, and address disparities among and within populations.

Figure 1. Preliminary Pediatric Universal Foundation measures.

Figure 2. Preliminary Adult Universal Foundation measures.

The Universal Foundation is intended to focus providers’ attention on measures that are meaningful for the health of broad segments of the population. On the administrative side, CMS says the Universal Foundation will aid the transition from manual reporting of quality measures to seamless, automatic digital reporting, and permit comparisons among various quality and value-based care programs to help the agency better understand what drives quality improvement and what does not.

These proposals aim to reduce provider and plan burden by streamlining processes, aligning resources, allowing providers to focus their attention on standards that are meaningful across populations, advancing equity, and aiding in reporting. The measures selected are also meant to outline many of the health problems associated with conditions such as depression, substance abuse disorders, morbidity, and mortality in the United States. Standardization may help to ultimately illustrate what drives the improvement of quality care—but comes with several potential implementation challenges. These include:

• Health plans have already created their own quality measures and might not want to use another set of newly created measures
• Providers are burned out and may not be interested in new initiatives
• Measures can become misaligned from their original intent or the intent of a program that adopted it
• There is still a lack of clarity around how, when, and where this Universal Foundation will be used

However, there are steps health plans can take now to prepare their program for success when the CMS Core Measures and the Universal Foundation are implemented. These include:

• Leveraging your EMR data and using it for care coordination
• Using your HEDIS^® and other population health data to understand the risk profile of your member population
• Working directly with your members to help them understand their own medical data so that they are familiar with their plan of care and physician's expectations

The ultimate goal is for health plans to work toward alignment between their own organizations, providers, and members. Don’t wait for CMS to confirm these changes and start getting ready to measure them now, as reporting could become mandatory as soon as 2024. Think of these efforts as setting a baseline for collecting, tracking, and benchmarking data so your organization is fully prepared once reporting becomes mandatory.

CMS's proposal to use consistent, nationally standardized quality measures in Medicaid, CHIP, Medicare Advantage, and Part D Advance Notice could ultimately lead to improved health outcomes and advance health equity. However, it is crucial to prepare for standardization across multiple programs and stakeholders by adopting best practices, identifying and overcoming barriers to adoption, and regularly monitoring progress.

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