A Proposed Framework for Integration of Quality Performance Measures for Health Literacy, Cultural Competence, and Language Access Services Proceedings of a Workshop (2018) / Chapter Skim
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4 Moderated Discussion with Implementer Panel 1
4 Moderated Discussion with Implementer Panel 1
Pages 37-48
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From page 37... ...
WILL THE PROPOSED APPROACH FACILITATE LITERACY, CULTURALLY, AND LINGUISTICALLY SENSITIVE PERSON-CENTERED CARE? James responded that this framework is shifting the focus of efforts into patient-centered care, but it will be important to keep track of what will be 1 This section is based on the comments of Cara James, director of OMH at CMS; Andrew Sanderson, medical officer at OMH at HHS; Michael Currie, vice president for the Health Equity Services Program at UnitedHealth Group; Foster Gesten, retired from his position as chief medical officer in the Office of Quality and Patient Safety for the New York Department of Health; and Margaret VanAmringe, executive vice president of public policy and government relations for the Joint Commission, and the statements are not endorsed or verified by the National Academies of Sciences, Engineering, and Medicine.
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From page 38... ...
"For a health insurance company in the business of care management and care support, trying to implement guidelines that are more specific toward care delivery organizations is sometimes a challenge," said Currie. "Sometimes, it is left up to interpretation and other times we morph and adjust them to fit our needs." His suggestion was to think about how these recommendations would apply to care delivery organizations separately from how they would apply to care facilitators or insurance organizations, given that they support patients and members in different ways.
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From page 39... ...
As an aside, he pointed out that the HHS OMH has compiled state legislative activities around the enhanced CLAS standards and provides that information on a state-by-state basis. This type of dashboard, said Sanderson, could provide peer-to-peer information that would enable health care organizations to compare their progress with comparable peers and learn from those comparisons.
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From page 40... ...
He also suggested establishing a systematic requirement associated with the recommendations for cultural competency training and to develop separate measures on whether an organization delivers culturally competent care and on member experience and satisfaction. "As we know, you can deliver quality care but not drive satisfaction, and conversely, you can be extremely satisfying to someone and deliver subpar care," said Currie.
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From page 41... ...
The HHS OMH, as well as other federal offices and agencies, have been trying to implement and adopt the CLAS standards since 2000. "We do not have any regulatory authority or mandate to make them happen, so we have to make sure that we align the positive things that are within those standards to things that a health care organization would do anyway to improve their patient care services," said Sanderson.
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From page 42... ...
James then commented that it is important to identify the goal for the framework. The discussion so far, she said, has identified equity as an end goal, but it also delved into the provision of culturally and linguistically appropriate services and addressing health literacy needs.
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From page 43... ...
If they are not cost-effectively leveragable, we do not." Speaking from his past experiences with the New York Department of Health and what he thinks states, in their role as purchasers and regulators, can do with the caveat about data limitations, Gesten said the ability to stratify quality metrics with some transparency would be a positive use of the framework. In his opinion, clearly integrating measures and quality improvement work into value-based purchasing strategies is a way to create the pressure or traction to adopt these measures.
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From page 44... ...
She noted that her office had been developing a portfolio of work called Building an Organizational Response to Health Disparities that aims to provide tools that providers can use to address disparities. The framework might also help with her office's ability to have continued conversations about MIPS as a means of achieving health equity and how to put more of a health equity focus into its work, as well as with her office's work with Medicare Advantage plans to support their efforts in the equity space.
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From page 45... ...
James said that she was interested in having research aimed at matching existing measures to the domains in the proposed framework as a means of reducing redundancy. She also would like to see research exploring how organizations with a PCMH designation perform on CAHPS measures for communication and patient experience compared to organizations without that designation.
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From page 46... ...
One of the challenges of this research is that payers and states are giving organizations substantial flexibility as to how they achieve the PCMH designation, and she said that having effectiveness measures could provide purchasers with leverage to require that certain standards are met by all PCMHs. Bernard Rosof noted that little work has been done looking at diverse populations and outcomes in PCMHs, accountability organizations, or other similar organizations.
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From page 47... ...
Rosof pointed out that in specific zip codes, vulnerable populations seek most of their acute, after-hours care in emergency departments, and he wondered how often programs to address equity, health literacy, cultural competence, and language access services reach the emergency department. James did not address emergency departments but noted that there are organizations collecting data on language, transportation needs, day care needs, social risk factors, immigration needs, legal needs, and other factors that might help support patients.
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From page 48... ...
48 INTEGRATION OF QUALITY PERFORMANCE MEASURES is an opportunity to step back, look at the framework, and identify what gaps exist. In her view, the goal should be to identify existing measures that would fill these gaps and offer the possibility of combining measures to avoid measurement overload, rather than looking for new ones.
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