Navigating the landscape of health care data exchange is complex, especially when seeking National Committee for Quality Assurance (NCQA) Data Aggregator Validation (DAV). For Health Information Exchanges (HIEs), this validation is crucial for demonstrating data integrity, reliability, and compliance.
Understanding NCQA Data Aggregator Validation
NCQA provides a nationally recognized standard for validating an organization’s ability to collect, aggregate, and standardize healthcare data for quality measurement and reporting, such as Healthcare Effectiveness Data and Information Set (HEDIS). It represents more than 72% of the U.S. population.
Data Aggregator Validation enables HIEs to save payers significant amounts of time and effort conducting their own primary source verification of patient data. For HIEs, achieving this validation can open doors to partnerships with health plans, providers, and other stakeholders who require data quality assurance. The process involves a rigorous assessment of an HIE’s data management practices, technical infrastructure, and compliance with NCQA standards.
Major Factors to Consider
Data Quality and Integrity
Data quality is paramount in NCQA Data Aggregator Validation. HIEs must ensure that the data they collect and exchange is accurate, complete, and consistent. Doing so includes implementing robust data validation processes, addressing data gaps, and resolving inconsistencies. Key considerations include:
- Data Standardization: Ensuring data is standardized using industry standards such as HL7 and FHIR.
- Data Validation: Implementing automated and manual processes to validate data accuracy and completeness.
- Data Governance: Establishing clear data governance policies and procedures to maintain data integrity.
Technical Infrastructure
A robust technical infrastructure is essential for successful NCQA Data Aggregator Validation. HIEs must have systems in place to securely collect, store, and exchange healthcare data, including:
- Secure Data Storage: Implementing secure data storage solutions that comply with HIPAA and other regulations.
- Data Exchange Capabilities: Ensuring interoperability with various healthcare systems and the ability to exchange data securely.
- Data Processing and Aggregation: Having the capacity to process and aggregate large volumes of data efficiently.
Compliance and Security
Compliance with regulatory requirements is a critical aspect of NCQA Data Aggregator Validation. HIEs must adhere to HIPAA, state regulations, and NCQA standards. Key considerations include:
- Privacy and Security Policies: Developing and implementing comprehensive privacy and security policies.
- Access Controls: Implementing strict access controls to protect sensitive data.
- Audit Trails: Maintaining detailed audit trails of data access and modifications.
Documentation and Reporting
Thorough documentation is essential throughout the NCQA Data Aggregator Validation process. HIEs must maintain detailed records of their data management practices, technical infrastructure, and compliance activities. This includes:
- Policy and Procedure Documentation: Documenting all data management policies and procedures.
- Technical Documentation: Maintaining detailed documentation of technical systems and processes.
- Reporting Capabilities: Ensuring the ability to generate accurate and timely reports for NCQA audits.
Common "Gotchas" and How to Avoid Them
Underestimating the Complexity
NCQA Data Aggregator Validation is a complex process that requires significant time and resources. Many HIEs underestimate the effort involved, leading to delays and challenges.
To avoid this:
- Plan Ahead: Start planning for validation well in advance and allocate sufficient resources for each step of validation. Given the time commitment associated with the NCQA Data Aggregator Validation cohort cycle, it is best to budget for dedicated resources, especially for functions such as Primary Source Verification (PSV) outreach and coordination. This portion of the work, in particular, requires heavy outbound communication and schedule coordination with data submitters, many of whom already deal with time pressures, competing priorities, and capacity constraints. Having a solid and proactive outreach plan is essential to completing all necessary work and documentation for submissions to the NCQA auditor within the cohort’s prescribed timeline.
- Understand Ingestion Site Responsiveness: When possible, construct ingestion site engagement scores, ranking, and most responsive contacts. Not all ingestion sites are responsive or communicate in a timely manner, and proactively managing the list of sites is essential to sticking to your cohort timeline.
- Seek Expert Guidance: Consider engaging consultants or experts with experience in NCQA Data Aggregator Validation. An HIE can outsource major components such as Project Management, Conformance, and Primary Source Verification to minimize overloading existing employees during the fixed cohort timeline.
Data Mapping Challenges
Mapping data from various sources to standardized formats can be a significant challenge. Inconsistencies and errors in data mapping can lead to data quality issues and validation delays.
To avoid this:
- Invest in Data Mapping Tools: Use robust data mapping tools such as conformance “schematrons” to automate and streamline error reduction workflows prior to the official cohort kick-off.
- Conduct Thorough Testing: Conduct extensive testing of data mapping and transformation processes as early in the project as possible and consider working on improving data quality at the source (data submitters) between cohort cycles.
Inadequate Security Measures
Security vulnerabilities can jeopardize the validation process and expose sensitive data. HIEs must ensure that their security measures are robust and compliant.
To avoid this:
- Conduct Regular Security Audits: Conduct regular security audits and penetration testing.
- Implement Strong Encryption: Use strong encryption for data at rest and in transit.
Documentation Gaps
Incomplete or inaccurate documentation can lead to validation delays and requests for additional information. To avoid this:
- Maintain Detailed Records: Maintain detailed records of all processes and activities as indicated in NCQA’s manual. Central and highly organized storage helps to avoid missing information and aids in making the NCQA Data Aggregator Validation process as repeatable as possible from year to year. Successful record-keeping includes internal processes and protocols needed for VAT, but also for Conformance and Primary Source Verification. For example, as you progress through a cohort, it is best practice to document especially challenging experiences, ingestion sites with high rates of data quality issues, trends pertaining to “failed cases,” and points of delay with specific ingestion sites, and then use insights from that collected information to guide approaches to minimize difficulties before and during the next cohort cycle.
- Review NCQA Data Aggregator Validation Manual Updates: Periodically, NCQA publishes revisions to their official documentation. It is important to check for updates before each cohort that could impact your anticipated or established workflows for program components such as Primary Source Verification.
- Regularly Review Documentation: Regularly review and update internal documentation to ensure accuracy and a more efficient response to major project phases, such as using the Validation Assessment Tool, responding to auditors’ questions, and preparing for subsequent validation cohort cycles.
Communication Challenges
Effective communication with stakeholders and NCQA is crucial throughout the validation process. Miscommunication or delays in responding to requests can cause issues. To avoid this:
- Establish Clear Roles and Responsibilities: Team members could handle a variety of work that either stays within a particular aspect of the project or cuts across domains (i.e., Project Management, Conformance, Primary Source Verification). Define team roles upfront and document communication expectations for each role (with whom they should communicate, through which mechanisms, and how frequently).
- Establish Clear Communication Channels: Establish clear communication channels (email, real-time chat software, etc.) and related procedures (sub-group definitions, stakeholder update methods and frequency, etc.) both internally as well as with external entities that participate in your NCQA Data Aggregator Validation cycle.
- Respond Promptly: Be prepared to respond promptly to requests from stakeholders and NCQA, and be mindful of the NCQA auditor’s time zone and submission deadlines. Their availability can impact turnaround times on questions, which can have a direct impact on deadlines. Some deadlines might also be “implied.” Careful attention should be paid to avoid missing important cut-offs during the cohort cycle.
Conclusion
NCQA Data Aggregator Validation is a significant undertaking for HIEs, but it is essential for demonstrating data quality and credibility for the HIE’s payer partners. By understanding the major factors involved in successful validation, addressing potential “gotchas,” and planning thoroughly, HIEs can successfully navigate the validation process and achieve this important recognition. Validation not only verifies the HIE’s capabilities but also enhances its reputation and opportunities as a healthcare IT industry leader.
Thank you to our partners at J2 Interactive for sharing this blog with the Civitas community!
