ANCOR Responds to CMS Request for Information on HCBS Quality Measures, Joins Coalition Comments

ANCOR submitted comments responding to the Centers for Medicare and Medicaid Services’ (CMS) request for information (RFI) on quality measures for the Medicaid Home and Community Based Services (HCBS) program. Members can find a refresher about the RFI here. For the convenience of our members, below is a summary of ANCOR’s key comments:

• An endorsed measure set needs to be more strongly focused on person-centeredness, the use of person-first language, and focused on assessing the individual’s personal satisfaction and general quality of life within the core measures set.
  • The measures presented lean heavily on those items which reflect the health of the system and not on recommended measures like autonomy, sense of belonging, and self-determination.
• The current version of the measure set does not reflect the needs and preferences of people with I/DD and are not I/DD-specific.
• As CMS and states move toward greater use of value-based payment approaches, they must ensure that base payments are sufficient, and that payment incentives do not substitute for adequate base rates.
• The number of measures identified is extensive. Is it the recommendation of CMS that states adopt all the measures identified, or is this intended to serve as a “menu” of possible measures from which states can choose?
  • Measures should minimize reporting burdens on providers.
  • Measures should consider variation in providers’ ability to report.
• Recommendation of a pilot project to incorporate and test life-satisfaction and personal outcome measures.
• Move toward a small but mandatory set of core measures and afford states the ability to customize extended measures to suit their service culture and stakeholders’ needs.

Additionally, as part of its coalition work with the Consortium for Citizens with Disabilities (CCD), ANCOR signed onto group comments on the RFI. The CCD comments issued recommendations on the following topics:

• Transparency and community input
• The need for measures that can be meaningfully implemented at the provider level
• Strengthening base measures related to community integration
• Elevating health equity
• Filling in key measure gaps
• Aligning quality measures with the HCBS Settings Rule to streamline oversight.