NASW Comments on NCQA's draft HEDIS

Joseph Thompson, MD
Vice President, Research and Measures Development
National Committee for Quality Assurance
2000 L Street, Suite 500
Washington, DC 20036

Dear Dr. Thompson,

The National Association of Social Workers (NASW) appreciates the opportunity to comment. Our membership of over 155,000 social workers practice in a variety of settings affected by managed care, including health, mental health, substance abuse, schools and child welfare. Our participation on NCQA’s Health Care Practitioners Advisory Panel has been very helpful in understanding the context of NCQA’s endeavors.

HEDIS has done groundbreaking work in the development of performance measures for managed care systems. We do have concerns and suggestions that we believe would make HEDIS an even better product. The rating scale is attached.

NASW is pleased that prevention is included in measuring quality in HEDIS, recognizing the value of prevention and early intervention for consumers and payors alike. But there are no measures that gauge screening for mental health or substance abuse conditions. Yet some 15 million American are affected by depression during their lifetimes—twice as many as are effected by coronary artery disease (Greenberg, 1993, J Clinical Psychiatry, 54:11). Embracing depression and substance abuse screening measures in HEDIS would be an important step to integrate behavioral healthcare with primary care.

As it pertains to medication management, this new measure is adequate, but it neglects the place of non-pharmacological methods of mental health treatment. Studies have indicated that mental health treatment must usually be given concurrent with medication for best results. The measure pertaining to follow-up includes primary providers as well as mental health therapist, without determining whether that primary care provider is providing mental health treatment or merely medication management.

In addition, other HEDIS measures could address clinical counseling as a treatment of choice. It appears that this measure assumes that medication is appropriate for all clients who fall within the designated categories of depression, regardless of their unique needs as individuals.

Additional comments have raised concerns about the Consumer Survey that we did not address when commenting on Accreditation 1999. The consumer survey inadequately addresses the interests of health practitioners and providers. In particular, the claims processing category asks questions of consumers that relate more to the providers’ experience. The consumer is unlikely to have access to all of the information about the claims processing experience. This could result in inflated claims of good service, based on incomplete data. Q32 asks about reasonable times for claims processing. Once the client makes the co-payment, is it likely they are attentive to information indicating whether the provider was paid on a timely basis?

Q33 asks about correct handling of claims. We have received numerous complaints from providers about claims lost repeatedly, inaccurate information that remains uncorrected after the correction has been transmitted, and conflicts between verbal statements made by MCO staff about coverage and the final claims decision. Once the provider irons out all of these wrinkles, the claims report the client receives may very well be correct. This question is useful to the extent that the consumer is privy to the provider’s experience with the MCO, but otherwise results could be misinterpreted.

NASW would also suggest that on page 111. #52, you change race to ethnicity. Change Native Hawaiian to American Indian or Alaska native category and leave Pacific Islander as a separate category. Also, will the survey be available in other languages?

NASW agrees that readmission is not a particularly useful measure with many mental health and substance abuse conditions, because they are often chronically relapsing conditions despite the best efforts in treatment. Follow-up after hospitalization for mental illness is a better measure of quality care. NASW would suggest this same follow-up measure for substance abuse treatment is also appropriate and as easily monitored.

Again, NASW appreciates the opportunity to comment. If you have questions, please contact me at 202/336-8218.

Sincerely,

Rita Vandivort, ACSW
Senior Staff Associate and Member, NCQA Health Care Practitioner Advisory Committee

For more information, contact Rita Vandivort at rvandivo@naswdc.org or call 800-638-8799, ext 218