It’s nice to have reason to take off my navigator hat for a change of pace. And a Request for Information (RFI) on proposed performance indicators for Medicaid and CHIP released earlier this year gave me a great opportunity to focus on another passion of mine – data to assess the effectiveness of our public coverage programs. It’s been a long while since Say Ahhh! featured the importance of performance data but that’s not because we don’t think it’s important. Let me start by recapping the previous discussion. More than a year ago, this blog highlighted two new reports on using data to assess and improve Medicaid and CHIP. And I skipped over another great report from the Maximizing Enrollment Initiative that recommends a core set of reason codes to use in reporting denials and disenrollments (my apologies to friends at NASHP and Mathematica).

One of the reasons I’ve been so excited about the new IT systems that Medicaid agencies around the country are building is that outdated systems can no longer be an excuse for not producing transaction and performance data. And indeed, one of the strings attached to the 90/10 federal matching funds for systems development is that states must comply with federal data reporting requirements. The performance indicators RFI finally gives us a glimpse of what CMS is proposing for standardized performance data on enrollment related actions impacting Medicaid and CHIP. Among our detailed comments on the specific measures, we had these topline recommendations to CMS:

Consider an incentive program that encourages states to prioritize the development of system capacity to collect and report performance indicators. We believe that reporting all of the indicators should be required of all states, but given that some states are far along in their IT development while others are still in procurement, we expect that states will need time to ramp-up their data collection and reporting capability. We hope CMS and other federal policymakers will consider an incentive program that encourages states to make collecting and reporting the performance indicators a priority, and rewards states for early and robust reporting. The performance bonus provision of the Children’s Health Insurance Program Reauthorization Action (CHIPRA) exemplifies the kind of incentive program that could be effective in advancing the reporting of performance indicators.

Move quickly toward establishing benchmarks and setting expectations for program improvement over time. Collecting and reporting data is not enough. It will be critically important for CMS to quickly collect and analyze baseline data and establish performance benchmarks.  Ultimately, the value in having data is to recognize where states are doing well and identify areas to make program improvements. A performance bonus program could evolve to reward states that show progress over time and meet or exceed federal benchmarks. To this end, CMS should work collaboratively with states and provide technical assistance to advance state analytic and process improvement skills and capacity.

Ensure that performance data are publicly reported promptly and on a regular basis. Public engagement enhances the effectiveness of government programs and improves the quality of policy decisions. To ensure the public trust and foster collaboration among states and stakeholders, transparency must be a priority. We strongly urge CMS to ensure that performance measures are publicly reported routinely and promptly. Ideally, CMS should make performance data available on Medicaid.gov on a timely basis when data is most useful.

Extend performance indicators to exchanges and add measures that span the continuum of coverage. Subsidized coverage through exchanges is an essential aspect of the continuum of coverage created by health reform. Performance data on public coverage programs are incomplete without consistent measures across Medicaid, CHIP and the exchanges. Additional measures should be established to track individual transitions in order to determine average length of coverage and identify gaps in coverage. Achieving longer periods of continuous coverage is a key strategy in improving health outcomes and holding managed care plans accountable for better care and reduced costs over time.

Standardize reason codes to ensure consistency and facilitate cross-state identification of best practices. The proposed performance indicators clearly show that states will need to track ineligibility and disenrollment reasons. As explained in our detailed comments, we strongly encourage CMS to specify a limited number of reason codes that will enhance comparability and learning across states.

While the RFI stated that comments received by March 8 would be appreciated, it’s not too late to share your own thoughts. Information on where to submit comments is included in the RFI. And if you’d like to see some examples of how data can be powerful, check out this report, which is one of my first contributions at CCF. It may be old(er) but it’s still good stuff!