Long-Awaited Rule on Mandatory Reporting of Child Core Set Quality Measures Proposed

Yesterday, CMS released its Notice of Proposed Rulemaking (NPRM) on the Child Core Set of Health Care Quality Measures in Medicaid and CHIP (known as the child core set). The proposed rule will implement the mandatory reporting of the child core set in 2024 as required by the Bipartisan Budget Act of 2018.

The NPRM, which is scheduled to be published on August 22, 2022, also includes rulemaking on mandatory reporting of the Adult Behavioral Health core set and on the quality of 1945 health home optional benefits in the 19 states that have implemented health home programs. Comments will be due 60 days after the NPRM is posted in the federal register.

Based on a quick scan, we’re excited to see that CMS is incorporating rules for stratification by race, ethnicity, sex, age rural/urban status, disability, language, or such other factors as may be specified by the HHS Secretary. Requirements for reporting measure stratification will be phased in over a five-year span, and will only be required if it is based on valid statistical methods and does not risk beneficiary privacy. The proposed rule would also codify the process of annually updating the quality measures in consultation with states and key stakeholders.

Mandatory reporting of these quality data is a major step forward in three ways:

  • It standardizes quality measurement in Medicaid and CHIP; states will no longer be allowed to deviate from technical specifications or take a pass on reporting.
  • It will serve as a catalyst for reporting disaggregated data, which is critical to identifying and eliminating health disparities.
  • It is a huge advancement in transparency and the accountability that will result from public reporting.

Medicaid and CHIP are the predominant source of health insurance, now covering half of the nation’s children. Mandatory reporting on the quality of care is an essential element in ensuring that children receive the care they need to get a healthy start and thrive in school and beyond. As the mantra goes in quality improvement, you can’t improve what you don’t measure. If you would like to learn more about the child core set and quality improvement in Medicaid and CHIP, check out our Medicaid Learning Lab quality session and this primer on quality. If you’re interested in seeing how your state scores on reported child core set measures, check out our State Data Hub.

Tricia Brooks is a Research Professor at the Georgetown University McCourt School of Public Policy’s Center for Children and Families.