CMS Releases NPRM on Mandatory Medicaid and CHIP Reporting

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In mid-August 2022, the United States Centers for Medicare and Medicaid Services (CMS) released a notice of proposed rulemaking to promote the consistent use of nationally standardized quality measures in Medicaid and the Children’s Health Insurance Program (CHIP).

Proposed Mandatory Annual State Reporting

The rule proposes requirements for mandatory annual state reporting of three quality measure sets: (1) the Core Set of Children’s Health Care Quality Measures for Medicaid and CHIP; (2) the behavioral health measures on the Core Set of Adult Health Care Quality Measures for Medicaid; and (3) the Core Sets of Health Home Quality Measures for Medicaid.

Core Sets

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 health care. They include a range of measures to determine how well Medicaid and CHIP are meeting their missions of providing affordable, high-quality, person-centered health coverage to low-income individuals. The Core Sets aim to evaluate how Medicaid and CHIP coverage is meeting the needs of individuals and their communities, including whether there are health disparities, and how the quality of care can be improved.

Health Home Benefits

In addition to the Child and Adult Core Sets, CMS wishes to establish through the NPRM reporting requirements for states that opt to implement at least one of the optional Medicaid health home benefits, which will measure health care quality for those states. Providers of the health home benefit report to the State on quality measures as a condition of payment. Health homes integrate and coordinate all primary, acute, behavioral health, and long-term services and supports for those with significant chronic conditions and/or serious mental health concerns. Currently, nineteen states and the District of Columbia have at least one health home program.

Effective Date

The NRPM would make reporting for the full Child Core Set, behavioral health measures in the Adult Core Set, and the two Medicaid Health Home Core Sets mandatory come FY 2024. The data reported in 2024 will reflect the care that was delivered in calendar year 2023.

Workgroups to Continue to Review and Potentially Modify Core Sets Measures

The NPRM notes that CMS has created a joint Child and Adult Core Set Annual Review Workgroup, to implement the statutory requirements and to ensure that measures in the Core Sets are meaningful for States and interested parties, feasible for State-level reporting, and represent minimal additional burden. Then, in 2021, CMS established a separate Health Home Annual Review Workgroup following the same structure and guidelines as the workgroup for the Child and Adult Core Sets, to develop and update the Health Home Core Sets.

The joint Child and Adult Core Set Annual Review Workgroup and the Health Home Annual Review Workgroup (“Workgroups”) are convened annually to develop recommendations on how to revise, strengthen, and improve the applicable Core Sets measures, and every year the Workgroups’ recommended changes are published for public comment. All meetings are announced in advance and open to the public.

Conclusion

“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,” said CMS Administrator Chiquita Brooks-LaSure. “CMS will use every lever available to ensure a high quality of care for everyone with Medicaid and CHIP coverage. By requiring states to report the core sets of quality measures, we can ensure that our policies are supported by data representing all of our beneficiaries.”

Comments on the proposed rule must be submitted to the Federal Register by October 21, 2022.

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