The NCQA Proposes Accreditation Standards for ACOs

On October 19^th, the National Committee for Quality Assurance (“NCQA”) issued draft criteria for accreditation of ACOs.  The NCQA is soliciting public comments on its draft criteria by this Friday, November 19^th at 5:00 EST.  Due to the extensive interest in ACOs, a very large volume of comments is expected.

NCQA’s goal for its draft criteria is to define evidence-based structure and process measures that can identify with reasonable accuracy which ACOs have the infrastructure necessary to achieve the triple aim of improving cost; quality; and patient experience.

ACO Levels: As initially envisioned, NCQA is proposing four possible levels of accreditation.  The levels will be progressive and will indicate the organization’s increasing capability to function as an accountable entity and achieve the triple aim (improved quality, increased patient satisfaction and lower per capita costs) as demonstrated through the accreditation process.  NCQA say that the levels will not vary depending on the organization’s structure (i.e. whether or not it is led by a multispecialty group, hospital or independent practice association) or whether it derives its incentive payments through a fee-for-service payment mechanism or chooses to accept some amount of financial risk (e.g. shared savings, global payment).   As initially drafted, the levels are:

 

• Level 1 – The applicant meets the core qualifying criteria which include standards for infrastructure (e.g. legal entity, leadership team, available primary care and specialty providers, etc.) and processes that promote good patient care and quality improvement (e.g. care coordination and managing patient transitions).

• Level 2 – The applicant meets the core qualifying criteria and has some advanced features which may include integration of electronic clinical systems and the ability to integrate data for reporting and quality improvement.

• Level 3 – The applicant meets the core qualifying criteria, possesses advanced features and can report standardized, nationally-accepted clinical quality measures, patient experience and cost measures.

• Level 4 – The applicant meets the core as well as advanced criteria and also demonstrates excellence or improvement in the metrics.

 

According to NCQA, the goal of the scoring levels is to “provide a reasonable, evidence-based set of expectations for organizations that can be used to qualify them as ACOs as well as provide them with a roadmap for achieving higher levels of capability.”

The draft accreditation criteria are arranged around 7 Categories of Standards being considered for Accreditation –

Category	Examples of Standards
Program Structure	-          The organization clearly defines its organizational and leadership structure. (PO1) -          The organization has the capability to manage its resources effectively. (PO 2) -          The ACO arranges for pertinent health care services and determines payment arrangements and contracting. (PO3)
Access and Availability of Services	-          The organization ensures that it has sufficient numbers and types of practitioners who provide primary and specialty care.(AA1)
Primary Care	-          Primary care practices within the ACO provide patient-centered care.
Care Management	-          The organization collects and integrates data from various sources, including, but not limited to electronic sources for clinical and administrative purposes. (CM1) -          The organization conducts an initial assessment of new patients’ health. (CM2) -          The organization uses appropriate data to identify population health needs and implements programs as necessary. (CM3) -          The organization provides resources for, or supports, the use of patient care registries, electronic prescribing and patient self-management. (CM4)
Care Coordination & Transitions	-          The organization can facilitate timely information exchange between primary care, specialty care and hospitals for care coordination and transitions. (CT 1)
Patient Rights & Responsibilities	-          The organization has a policy that states its commitment to treating patients in a manner that respects their rights, its expectations of patients’ responsibilities, and privacy. A method is provided to handle complaints and to maintain privacy of sensitive information. (RR1)
Performance Reporting	-          The organization measures and reports clinical quality of care, patient experience and cost. (PR 1); -          At least annually, the organization measures and analyzes the areas of performance and takes action to improve effectiveness in key areas. (PR2)

 

Under each Standard are several elements, intended as components which must be proved if the organization is to meet the larger standard.  Each element also includes information on what an organization must submit to establish it has met the element.  No scoring had been developed as of the date the draft criteria were published.

In addition to comments on any of the proposed Standards or elements for accreditation, NCQA is specifically seeking comments on several issues concerning its ACO accreditation criteria, including,

-          What capabilities are expected for a Level I accredited ACO as compared with ACOs accredited at other levels;

-          Whether the proposed eligibility criteria capture the types of organizations that have the ability to act as ACOs.

-          Whether certain types of specialists should be specified to be included in an ACO and whether it is necessary to further specify whether and how they are part of the organization’s legal structure.

-          How a newly formed ACO can be judged if many of the criteria require measuring performance over some prior period.

The NCQA Draft Criteria and instructions for submitting comments can be found online at  http://www.ncqa.org/tabid/1267/Default.aspx