2016-01-08 National Governors Association

Medicaid Data and Reporting

The Honorable Orrin Hatch
Chairman
Committee on Finance
United States Senate
219 Dirksen Senate Office Building
Washington, D.C. 20510

The Honorable Ron Wyden
Ranking Member
Committee on Finance
United States Senate
219 Dirksen Senate Office Building
Washington, D.C. 20510

Dear Chairman Hatch and Senator Wyden:

The National Governors Association (NGA) appreciates the opportunity to provide the following information regarding data gaps and opportunities to streamline Medicaid reporting. Working together with governors and other key stakeholders, your continued focus in this area is critical to supporting governors’ health care transformation goals and the long-term sustainability of the Medicaid program.

Employing Data More Effectively to Strengthen Medicaid
NGA shares your interest in improving the quality and accessibility of Medicaid data, both for traditional program integrity purposes and for transforming the health care system to provide higher-quality, more efficient care. Like you, governors are seeking timely, accurate data to inform policymaking and better understand how their programs are performing. Governors also are working hard to ensure providers have the information needed to improve outcomes for their patients.

The NGA Center for Best Practices is supporting governors in those efforts, helping them drive health care transformation with better data and improved analytics. Through the complex care policy academy, for example, NGA is helping states use data to identify and improve care for some of the costliest Medicaid patients whose complex care needs are not being met by the current health care system. [1]

Governors face a number of challenges as they strive to use data more effectively in Medicaid. Much like the private sector, states are struggling to migrate data systems built primarily for payment and adjudication of claims to systems that support delivery system transformation through the use of real-time information and rapid-cycle evaluation. For this reason, NGA also is working with states, national experts, the Centers for Medicare and Medicaid Services (CMS) and data vendors to identify and implement new purchasing strategies to modernize state Medicaid data systems.

There are other important sources of data – beyond Medicaid – that are critical for governors seeking to improve the quality and efficiency of health care services in their states. Medicare data, for example, is one of the biggest gaps identified by governors who are working to deliver better, higher-quality and more efficient care for individuals dually eligible for Medicare and Medicaid. The CMS State Data Resources Center is doing important work in this area. However, states and health care providers still often lack access to the timely Medicare data needed to improve outcomes and lower the cost of care for dual-eligibles.

Fostering a System of Meaningful Reporting through Collaboration with States
As you undertake your review of Medicaid reporting, NGA urges you to ensure required reporting yields actionable information for both state and federal policymakers. Requiring states to report information that goes unused by CMS, or that lacks a clear link to shared state-federal policy goals, is an inefficient use of resources by states and the federal government. The U.S. Department of Health and Human Services already has limited capacity to analyze and use Medicaid claims, quality and other data submitted by states. Creating additional reporting requirements for states will not improve the Medicaid program unless those requirements are developed in collaboration with governors and their Medicaid directors and clearly enhance the ability of both state and federal leaders to understand and improve the quality and efficiency of care provided through Medicaid.

Streamlining Reporting for Section 1115 Medicaid Demonstration Waivers
NGA appreciates ongoing federal efforts to streamline monitoring and reporting for Section 1115 Medicaid waiver demonstrations, a key vehicle for health care transformation. In July, CMS announced that it will be reviewing existing Medicaid data systems and revising Section 1115 monitoring requirements to reduce duplication and lessen the administrative burden for states. This undertaking is especially important as more states transition to the Transformed Medicaid Statistical Information System (T-MSIS), which has the potential to improve the ability of Medicaid data to be compared and analyzed within and across states and may eliminate the need for states to report certain information separately.

CMS could further streamline Section 1115 reporting for longstanding waivers with demonstrated outcomes by shifting reporting requirements to focus more on the shared, overarching policy goals of the waiver (for example, overall quality, access and efficiency goals) as opposed to the more granular reporting requirements needed for newer, untested waiver programs. Short of developing a “pathway to permanency” for mature waivers, as previously recommended by governors in the 2014 NGA Health Care Sustainability Task Force report, CMS could reduce the administrative burden on states and strengthen accountability by focusing on a streamlined set of outcomes-focused measures. Such an approach would promote better oversight of Medicaid programs and a reduction in the number of state reports that go unused by CMS.

Ensuring T-MSIS Is a Tool for States and Federal Policymakers
States have invested significant resources in implementing and addressing challenges associated with the rollout of T-MSIS. CMS should view this undertaking as a complete partnership with states, one that is critical to ensuring states as well as the federal government have timely and accurate data to inform decision making. For this reason, CMS should make aggregate, non-aggregate and analyzed data available confidentially to states for the purposes of benchmarking, quality improvement and measuring efficiency.

Taking a More Strategic Approach to Quality Reporting
Governors should continue to have flexibility in choosing the quality measures that are most meaningful for their Medicaid programs; there is a role, however, for the federal government in establishing a national framework for quality measurement in Medicaid and the larger health care sector. The recent proliferation of health care quality metrics has become onerous for states and health care providers, while providing little corresponding benefit in terms of improved quality and outcomes. Federal policymakers should address this by working with governors and other stakeholders to identify a core set of aggregate measures that reflect key policy goals and health indicators. The Institute of Medicine’s 2015 Vital Signs report underscores how the widespread use of a limited set of standardized measures could reduce the burden of unnecessary measurement and align quality improvement activities between Medicaid, Medicare and the private sector. The streamlined set of aggregate measures recommended in the report should be considered in any federal effort to enhance the efficiency and effectiveness of quality measurement in Medicaid.

Thank you for the opportunity to inform your review of Medicaid data and reporting. NGA stands ready to work with you to ensure governors and their federal partners have the information needed to yield better health at a lower cost for Medicaid enrollees.

Sincerely,

Scott D. Pattison
Executive Director/CEO
National Governors Association

For additional information about how states are using Medicaid data to address the needs of the Medicaid complex care population, please see NGA Issue Brief “Using Data to Better Serve the Most Complex Patients” (September 14, 2015).