Changes to the Colorectal Cancer Screening Measure & Transition to ECDS

The Electronic Clinical Data Systems (ECDS) domain of the HEDIS® measurement set has been expanding since NCQA’s introduction of this novel reporting framework in 2015. The use of electronic clinical data for quality measurement facilitates connectivity between payors and providers to improve the efficiency of reporting and to make data available to care teams. For more background on the requirements for ECDS reporting, read our "HEDIS® MY2020 Data Management – Expanding Use of Electronic Clinical Data Systems" blog.

For Measurement Year 2022 (MY2022), NCQA will continue to support health plans reporting the colorectal cancer screening measure in either the traditional reporting method (COL) or using the ECDS method (COL-E). Both colorectal cancer screening measures have been modified for MY2022 to align with updated guidelines from the U.S. Preventive Services Task Force. There are several significant changes to the measure[1]:

• The age range has been revised from 50-75 years to 45-75 years
• The hybrid specification indicates that sample size reduction is not allowed
• Stratification for race and ethnicity is required
• A Medicaid product line has been added with an administrative specification only

NCQA has also indicated the colorectal cancer screening measure will be transitioned to ECDS-only reporting for Measurement Year 2024[2].  Likewise, CMS has affirmed its alignment with NCQA’s technical specification for Medicare Advantage Star Ratings[3] and the Health Insurance Marketplace Quality Rating System[4].

Upcoming data collection challenges

This specific measure already creates multiple challenges for health plans, which are only exacerbated by these changes.

1. The eligible population for this measure is defined by some minimal demographic and eligibility characteristics. In fact, members only need to be eligible in the most recent two years. This means the denominator is typically relatively large. By lowering the age range by five years, the denominator for commercial health plans may be substantially larger.
2. Depending on the type of test used for screening, health plans may need to look back as much as 10 years for historical screenings. This lookback period far exceeds the eligible period required for the measure, meaning that health plans may be requesting records for services they did not pay for. Providers may be hesitant to provide this health information without proper incentives tied to closing care gaps.
3. CMS has indicated that the change in age group represents a substantial change in the specification and that colorectal cancer screening will be moved to the display measures for two years. CMS also indicated that the legacy measure for members 50-75 years old could be extracted from the new measure and will remain in the Star Ratings. However, health plans will not be able to draw a hybrid sample only for ages 50 and above and they will not be able to reduce the sample size this year.

The colorectal cancer screening measure was available for optional ECDS reporting starting in Measurement Year 2019. While administrative rates were similar to ECDS rates, NCQA found that hybrid rates were higher than ECDS rates by an average of six percentage points for commercial and 10 percentage points for Medicare[5]. Health plans are highly reliant on medical record review, and particularly unstructured data in the clinical record, to identify these screenings.

Evaluate and prepare for ECDS reporting

Health plans should take advantage of parallel reporting using the traditional method of reporting the COL measure along with the ECDS reporting method for COL-E. Administrative rates should very closely align with ECDS rates. When rates differ, evaluate the sources of data used by each. In traditional reporting, sources will be identified as administrative (derived from claims) or supplemental (either standard supplemental or non-standard supplemental). These sources may need to be identified differently for ECDS reporting, using the Source System of Record (SSoR). HEDIS ECDS reporting requires categorizing data sources into the following SSoR categories:

1. Electronic health record (EHR)/personal health record (PHR).
2. Health information exchange (HIE)/clinical registry.
3. Case management registry.
4. Administrative.

Once traditional and ECDS reporting are producing similar rates, strategize how to acquire clinical data that will enable ECDS performance to be comparable to hybrid rate performance.

Prioritize clinical data

In the spirit of the ECDS framework, primary clinical sources should be prioritized. This would include EHR data accessible via Fast Healthcare Interoperability Supplemental Resources (FHIR) or continuity of care documents in the standard HL7 Clinical Data Architecture schema (C-CDA). These sources may also provide insight into race and ethnicity for stratification in the colorectal cancer screening measure. Read our "Addressing Health Disparity: Importance and Impact for HEDIS" blog on this new stratification requirement. Standardized, file-based exchange from other clinical sources may supplement rates.

Value-based contracts or other incentives to providers produce opportunities to gain access to these new data sources. Regional or statewide Health Information Exchanges (HIEs) are also useful sources for standardized data exchange.

Supplemental medical record review continues to be a viable option to fill identified data gaps; however, no systematic sample will be applied once the colorectal cancer screening measure transitions to ECDS. For most health plans, there would simply be too many records to procure for medical record review; however, this remains a valuable tool for specific circumstances—for example, paper-based practices.

Consider the downstream impact of data sources

Keep in mind that each new data source is subject to auditor review and may require primary source verification. The auditor will want to review policies and procedures regarding data collection and file formats. Additional information regarding quality control and standard processes needs to be documented. Data that are considered non-standard supplemental sources, e.g., data abstracted via medical record review, must be supported with proof of service documentation that contains all the elements required for the measure. Since auditor approval is required by the March validation deadline, health plans need to consider the lead time required for the review process in their annual project planning.

While the move to ECDS measures can be a challenge, SS&C Health is committed to your success. Our HEDIS solutions include NCQA-certified measures within SS&C® CareAnalyzer, while Clinical Repository provides connectivity to FHIR resources, and can consume C-CDA documents or support supplemental medical record review. Download our "HEDIS ECDS Transition Guide" to learn how NCQA’s planned measure transition will affect your health plan. For more information on ECDS and how it will impact your plan, refer to our other HEDIS blogs on this topic: "HEDIS Expansion of Digital Measures: Preparing for 2022 Reporting" and "HEDIS: Public Reporting is the Next Phase for ECDS".