June 23, 2025

Quality Measures Specification Update
MHDC continues to update its Quality Measures flat file specification, incorporating changes approved by participants in the Data Governance Collaborative (DGC). These updates reflect new health equity reporting requirements from Massachusetts and NCQA’s Health Equity Accreditation programs. Additional revisions account for industry changes (e.g., mergers and acquisitions) and other minor adjustments.

Key enhancements include:

• Six new data groups, including the ability to capture questionnaire data, SDOH interventions, disability information, and more.
• Seventeen new demographic properties within the membership data group, including sexual orientation and gender identity (SOGI), religion, housing status, and English proficiency.
• Mechanisms for capturing multiple values for key demographic data elements.
• Metadata concerning the collection/validation of key demographic data elements.

Please note that the overall size of the specification will more than double as a result. MHDC plans to release a draft for DGC review later in 2025, with a finalized version to follow. MHDC will also convert the updated specification to FHIR for use under NEHEN services.

CMS RFI Responses
The DGC provided input on two recent CMS Requests for Information (RFIs):

• Unleashing Prosperity Through Deregulation of the Medicare Program
• Health Technology Ecosystem

MHDC submitted public comments in June, with both responses emphasizing the importance of local, multi-stakeholder collaboration in fostering innovation and interoperability. Key recommendations included:

• Accelerating a digital health economy powered by real-time, high-fidelity data.
• Promoting innovation to enable scalable, standards-based data exchange.
• Ensuring access to clinical and claims data to reduce burden and support value-based care.
• Encouraging CMS to align national policies and incentives with state-led data-sharing efforts.

Read both comment letters [here].

December 11, 2024

We are pleased to welcome Lauren Bedel to the DGC to supplement our existing team. She brings an extensive policy background to the group and is working diligently to learn about data standards, data quality, interoperability, and other topics we discuss. We know she will be a valuable addition.

The requirements for the MHDC Quality Measures specification have been finalized and approved by participants in the DGC; specification updates are underway. These are extensive changes mainly to incorporate health equity data required by Massachusetts and for NCQA’s Health Equity accreditation programs. It also incorporates industry and community changes since the last update (such as mergers and acquisitions) and a few other small adjustments.

For those of you using the spec who may not have participated in the discussions leading to the finalized requirements and exact plans for how to integrate them into the specification, be aware that the specification will more than double in size from this update, including:

• six new data groups including the ability to capture questionnaire data, SDOH interventions, disability information, and more

• seventeen new demographic properties in the memberships data group covering areas such as sexual orientation and gender identity, religion, additional language information including English proficiency level, and housing status

• mechanisms for capturing multiple values for some key demographic data elements

• metadata concerning the collection/validation of key demographic data elements

The DGC is currently on an extended hiatus until January 8 as we work on implementing these plans. Meetings early in 2025 will likely be focused on addressing any unexpected issues that come up during this work.

In addition, the DGC continues to keep tabs on industry activity and review new laws and regulations around data, interoperability, health equity, price transparency, privacy and security, and patient access. Our major comment since the last update was on ASTP's HTI-2 rule, an expansive rule covering many new certification options including for payers and public health authorities as well as advances in USCDI versions, API expectations, pharmacy interoperability, and public health interoperability among other things. In addition, we commented on other proposed rules as well as quite a few policy guidelines and reports including federal strategic plans for health IT, federal approaches to health equity, and federal recommendations for FHIR adoption. We also responded to a congressional RFI asking about implementation of the 21st Century Cures Act and soliciting suggestions about additional areas that should be covered in future legislation. All of these and our other regulatory comments can be found on our Comments and Letters page.

The DGC also serves as a feedback mechanism and incubation area for NEHEN 3.0, although some of this activity may be transferring to NEHEN itself as we move closer to implementation. Look for news on exactly how we're reorganizing some of our activities in the near future.

April 15, 2024

The DGC has started updating the MHDC Quality Measures Specification, mainly to incorporate health equity data required by Massachusetts and for NCQA’s Health Equity accreditation programs. This is a community-wide, collaborative process; we encourage all DGC participants to contribute to the project either via discussions at our working group meetings or via email  or other avenues when meeting attendance is not possible.

In addition, the DGC continues to keep tabs on industry activity and review new laws and regulations around data, interoperability, health equity, price transparency, privacy and security, and patient access. In the past several months, we have reviewed and submitted comments on RFIs or proposed rules from CMS, ONC, NCVHS, and NCQA on topics as varied as provider disincentives related to information blocking, the USCDI v5 draft, ICD-11, and upcoming quality measures requirements and guidance. We have also been reviewing the final version of the CMS Advancing Interoperability and Improving Prior Authorization rule in detail as a group. We expect to look at the final version of the OMB race and ethnicity proposal, the upcoming HTI-2 proposed rule (expected at any time), the Federal Health IT Strategic Plan proposal, and more in the next few months.

The DGC also serves as a feedback mechanism and incubation area for NEHEN 3.0 plans. We regularly discuss progress, solicit feedback, encourage participation in RFP review activities, and more.

We look forward to your participation in this critical work.

 

December 14, 2023

The DGC continues to keep tabs on industry activity and review new laws and regulations around data, interoperability, health equity, price transparency, privacy and security, and patient access. In the past several months, we have reviewed and submitted comments on RFIs or proposed rules from CMS, ONC, FDA, OCR, the Senate HELP committee, and more on topics as varied as proposed changes to the Hospital Price Transparency rule (since finalized), changes to interoperability and more at the NIH, rules to reduce discrimination against the disabled in health care, and new requirements to simplify patient information about prescription medications.

The DGC also serves as a feedback mechanism and incubation area for NEHEN 3.0 plans. We regularly discuss progress, solicit feedback, encourage participation in RFP review activities, and more.

We are currently reviewing proposals around provider disincentives to information blocking and proposed changes to the No Surprises Independent Dispute Resolution process. In addition, we anticipate a new ONC rule HTI-2 to review and common upon at any time. We also believe final versions of ONC's HTI-1 rule and the CMS interoperability and prior authorization rule first proposed approximately a year ago will be released in the near future; the DGC will look at them in detail once they're available.

The DGC is taking its standard two week end of year hiatus but will resume weekly meetings on January 3. We hope you join us in this important work.

 

July 12, 2023

The DGC has been busy addressing the tsunami of regulations coming our way. Since the last update, we have submitted the following regulatory comments with varying levels of detail:

• HHS OCR HIPAA Privacy Rule to Support Reproductive Health Care Privacy Comment (HHS-OCR-2023-0006-0001), submitted June 15, 2023
• ONC Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (HTI-1), submitted June 20, 2023
• NCVHS ICD-11 RFI, submitted June 28, 2023
• ONC USCDI+ for Quality Draft Dataset, submitted June 29, 2023

We are also working on several more comments due in July or August and triaging new regulatory activity as it happens to prioritize what we bring to the DGC working group for discussion/what we comment on as a group.

The ongoing deluge of regulatory releases has kept us busy, but the DGC is also participating in ongoing industry activity in areas such as quality measures, price transparency, AI and machine learning, and value based care to help inform our work.

As always, please let us know if there’s a particular regulatory document you’d like us to consider reviewing or if there’s a particular type of data or care you’d like to see as the topic of a future deep dive.

June 1, 2023

We recently finalized a comment to the Agency for Healthcare Research and Quality (AHRQ) on barriers to access to preventative care for disabled patients. This comment was based on discussions in the DGC working group on the type of data to collect about accommodations in a healthcare setting and discussions on policies that impact patients with SDOH issues in one of our deep dives. You can find a copy HERE.

The DGC working group is still reviewing the ONC proposed rule covering new health IT certification requirements, changes to information blocking, transparency and data governance of AI used by certified health IT, and more. We plan to submit a comment before the June 20 deadline.

Several other regulations, proposed rules, standard operating procedures, and RFIs have been released recently and the DGC is determining which ones to review in detail and potentially comment on. We are still looking at the proposed rules mentioned in last month’s update as well as a new White House RFI on national priorities for AI found HERE.

As always, please let us know if there’s a particular regulatory document you’d like us to consider reviewing or if there’s a particular type of data or care you’d like to see as the topic of a future deep dive.

May 1, 2023

We finalized our comment on the CMS Attachments NPRM and submitted it to CMS prior to the April 21 deadline. It focused on two major areas: coordination of rules and adding support for FHIR as both a data format and exchange mechanism. You can find a copy HERE. 

ONC released a proposed rule covering new health IT certification requirements, changes to information blocking, and more on April 18. One of its major areas of focus is transparency and data governance of AI used by certified health IT. We have started reviewing this rule in the DGC working group and plan to submit a comment before the June 20 deadline.

Several other regulations, proposed rules, standard operating procedures, and RFIs have been released recently and the DGC is determining which ones to review in detail and potentially comment on. Among other options, we are specifically exploring the HHS OCR proposed HIPAA privacy rule covering reproductive health data and the FTC RFI on cloud computing.

We are also evaluating future deep dives into the data and exchange needs of specific types of data or specific types of care and other panel discussions and presentations. If you have a topic you’d like to see us tackle, let us know!

April 1, 2023

We completed our detailed discussions on the CMS Advancing Interoperability and Improving Prior Authorization Processes NPRM and submitted a comment, available HERE. We also finalized and submitted comments on the OMB Initial Proposals for Updating Race and Ethnicity Statistical Standards (available on the same page linked above).

CMS extended the comment period for the Attachments NPRM and we now plan to submit a limited comment discussing the need for FHIR support in addition to x12 and C-CDAs.

Our latest deep dive on physical therapy was held on March 30. We learned a lot and plan to continue holding deep dives to explore the data and exchange needs for specific types of data or specific types of care. If you have a topic you’d like to see us tackle, let us know!

March 1, 2023

Follow our weekly quick industry updates on YouTube or look for Twitter announcements using #massdatagov.

We continue to explore the CMS proposed rules released in December, particularly the Advancing Interoperability and Improving Prior Authorization Processes NPRM released on December 13, 2022. We plan to submit a comment on this rule - feel free to contact us if you have something to contribute.

We also examined the OMB Initial Proposals for Updating Race and Ethnicity Statistical Standards and have a draft response for DGC members to review based on comments and thoughts from both DGC staff and participants - we’re happy to share the final document with any MHDC member - just ask us!

Our equity training project for Blue Cross Blue Shield of Massachusetts is moving into its final phase, with the third set of planned training sessions scheduled to take place in March and April. Combining information on relevant regulations, data and data exchange standards, and takeaways from our experience working with payers and providers on data exchange, we’re pleased to help the community understand the requirements and challenges of exchanging data for health equity projects and other purposes.

Our next deep dive will be held on Thursday, March 30 from 2-4pm. It will look at the special data and exchange needs related to physical therapy. You can register HERE. See you there!

February 1, 2023

We continue to record the quick industry updates section of the weekly working group meetings and encourage anyone interested in health data, interoperability, federal regulations, and the state of the industry to watch. These are new items we sometimes haven't fully digested yet, hot off the presses. If you're interested, the videos are posted on YouTube and announced on Twitter - look for our DGC hashtag #massdatagov to find them. If you like what you see and want to participate in deeper discussions on similar topics, please email us - it's free for payer and provider MHDC members.

We've started exploring the CMS proposed rules released in December, most notably the Advancing Interoperability and Improving Prior Authorization Processes NPRM released on December 13, 2022. This rule is wide ranging, including additions and changes to the May 2020 interoperability rule as well as new Provider Access APIs for payer => provider exchange of administrative and clinical data, new real time electronic prior authorization requirements, new quality measure and reporting requirements, and more. Learn more about it in this month's featured article.

Watch this space for more information about future deep dives and our equity-related consulting work as these projects progress.

December 15, 2022

We've started recording the quick industry updates section of the working group meetings to share a small bit of what we do in the DGC with the wider world. We call these quick updates even though we take our time to discuss our initial impressions of each update because we often delve deeper into the regulations, RFIs, reports, or other items under discussion in the main section of future meetings. These are new items we sometimes haven't fully digested yet, hot off the presses. If you're interested, the videos are posted on our YouTube channel and announced on Twitter - look for our DGC hashtag #massdatagov to find them.

The main thrust of our recent deeper discussions have revolved around sessions at the WEDI National Conference at the end of October. We've spent time looking at the role of NCVHS in the HIPAA advancement process, talked about TEFCA, looked at some of the issues most affecting patients and patient data, further explored questions and concerns around the GFE and AEOB process in the No Surprises Act, and discussed updates from OCR, CMS, ONC, HL7, and NCQA.

We will resume Deep Dives in 2023. We've also been exploring several special projects with our Steering Committee and lending our expertise to some external projects run by others, including a project with Blue Cross Blue Shield educating some of their providers on interoperability, data standards, regulations, and related topics with an eye toward equity - watch this space for more information as these projects progress.