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July 29 -- The Office of Minority Health (OMH), Centers for Medicare & Medicaid Services (CMS), Department of Health and Human Services (HHS), invites public comments to OMB by August 30, 2021 regarding the Medicare Beneficiary Experiences with Care Survey (MBECS) System.
 
The MBECS system is designed to conduct population specific surveys that will be administered to the group of interest, fielded one time. This means that over the three-year period, two individual surveys will be administered. This will allow CMS OMH to respond quickly to the data needs of stakeholders with interests in these underrepresented groups. Data collected through the MBECS system will be used to better understand—and thus serve the needs of—Medicare beneficiaries in minority populations. The core questionnaire will collect information on communication with medical professionals, coordination of health care, experiences getting needed health care, experiences with personal doctors and specialists, and key demographics. Data will be compared to benchmarks from the FFS CAHPS, MA CAHPS, and NAM CAHPS surveys. The population-specific questionnaire module described and submitted via a specific collection request will collect information about issues most relevant for that particular group of interest.

CMS’s Quality Strategy highlights the agency’s commitment to working towards Health and Human Service’s (HHS) goal of eliminating health disparities in the United States. Although defined differently depending on the context, health disparities generally refer to systematic differences in health outcomes and quality of health care experienced by specific minority groups. Due to the relative size and, in some cases, the unique characteristics of minority populations, national general population data collection efforts often do not include adequate representation of minority populations because they do not sufficiently oversample the relevant minority groups; this makes subgroup analyses challenging, if not impossible. In addition, many national surveys of the general population do not collect data points that would enable researchers to identify these minority groups for analysis (for example, an indicator of disability or substance abuse that would enable comparison to the general population).  

Thus, a tailored data collection approach helps to understand the experiences of minority populations. The proposed umbrella data collection system, the Medicare Beneficiary Experiences with Care Survey System (MBECS System), will help address these issues by using a standardized yet flexible methodology that allows for customization in approach and content based on the particular minority group(s) of interest. The flexibility of design for each individual survey will be driven by the data, data sources, and location of the data for the population of interest.

The umbrella MBECS system will use an expanded Consumer Assessment of Healthcare Providers and Systems (CAHPS®) methodology as a standardized data collection vehicle for Medicare beneficiaries in minority populations. First, CMS OMH will develop a survey, which includes a “core” set of existing CAHPS questionnaire items. The outreach method, modes of administration, and data collection protocols will be identical across survey populations. When a specific population of interest is identified, CMS OMH will then submit an individual collections request to OMB, including a revised research and sampling plan with changes relating to the specific population of interest. These individual submissions will include the core CAHPS questionnaire plus a brief population-specific module. The brief module will include population-specific questions pulled from Federal surveys relevant to the minority population, for example: the National Health Interview Survey (NHIS), the Medicare Current Beneficiary Survey (MCBS), or the Current Population Survey (CPS). CMS OMH will also provide updated respondent materials with wording adjusted for that particular population. Each survey submitted as an individual collections request will focus on one minority group; different minority groups of interest will not be surveyed at the same time or be administered the same population-specific module.
 
Key to the success of collecting data from minority groups is a sampling plan that ensures adequate representation of the target population in the final analytic sample. CMS OMH proposes building the MBECS data collection system by capitalizing on three main sources. These include: existing beneficiary characteristic flags within the CMS Virtual Research Data Center (also known as the Chronic Conditions Warehouse, or CCW), International Classification of Diseases – Tenth Addition (ICD-10) codes from CMS’ Medicare-Fee-For-Service (FFS) “final action” claims from institutional and non-institutional providers, and algorithms that leverage these data sources to identify beneficiaries who are likely in the population of interest. The a priori identification of beneficiaries likely to be in the population of interest will enable CMS OMH to target individual data collection efforts to the intended population and thus ensure adequate representation in the sample. The alternative approach–screening a general population of beneficiaries in order to identify minority population—would duplicate some existing data collection efforts and is cost prohibitive.

The goal of this umbrella data collection effort is to gather data via separate surveys on a variety of minority Medicare beneficiaries’ experiences. Topics and questions of interest may ask about beneficiaries’ communication with medical professionals, coordination of health care, experiences getting needed health care, and experiences with personal health care providers and specialists. CMS OMH will compare survey data to benchmarks from the general population of Medicare beneficiaries while controlling for population characteristics, as appropriate.

To achieve the goals of the MBECS system, CMS OMH will identify Medicare beneficiaries in priority minority populations of interest through review of administrative data and conduct data collection via a sequential multi-mode (web, mail, and telephone) survey that includes the module specific to one group of interest. CMS OMH will conduct up to three separate MBECS surveys over the course of this 3-year clearance. The groups considered to be priority minority populations for CMS OMH are Medicare populations that experience disproportionately high burdens of disease, worse quality of care, and barriers to accessing care. For CMS, these populations include but are not limited to, persons with intellectual or developmental disabilities, persons with mental illness, or persons with substance abuse disorders. Thus, candidates for survey through the MBECS umbrella system include beneficiaries who are:
•    diagnosed with severe mental illness and/or intellectual or developmental disability
•    diagnosed with substance use disorder

Subpopulations of interest within these two key groups include Hispanic, Non-Hispanic Black or African American, and Non-Hispanic Other, including White beneficiaries. Additional demographic comparisons (e.g., rural vs. urban, age group comparison, race/ethnicity comparisons) can be made to benchmark estimates for the population of interest, where possible.

CAHPS surveys ask health care consumers and patients to report on and evaluate their experiences with health care. These surveys, developed by the Agency for Healthcare Research and Quality (AHRQ), cover topics that are important to health care consumers and patients and focus on aspects of quality that they are best qualified to assess, such as the communication skills of providers and ease of access to health care services. The MBECS core questionnaire (see Attachment A) administered to every group of interest includes items from the 2016 (or most current) CAHPS survey of the Medicare Fee-for-Service population (FFS CAHPS), the 2016 (or most current) Medicare Advantage and Prescription Drug Plan CAHPS (MA CAHPS) questionnaire, and the 2014-2015 Nationwide Adult Medicaid CAHPS (NAM CAHPS) questionnaire. Some demographic items are included in order to align with HHS implementation guidance related to the Public Health Service Act (42 U. S. C.). Specifically, the demographic items were expanded to align with HHS guidance, and items related to disability and limited English proficiency are included. As the CAHPS questionnaires noted above are updated, CMS OMH will update the MBECS core questions, using CAHPS as a benchmark. The data collection activities proposed for the MBECS umbrella system and individual surveys will align closely with CAHPS methodology, using a sequential multi-mode (web, mail, and telephone) approach. Data analysis of each individual survey will include comparison of MBECS survey estimates against FFA, MA, and NAM CAHPS benchmarks and/or other source surveys for the population-specific module questions.

Data gathered through the MBECS system will allow CMS OMH to understand and measure differences in the experiences of minority Medicare beneficiaries compared with those of the general Medicare population. This data will inform CMS OMH policies, priorities, and future initiatives, as the agency strives to reduce health disparities.

This study is being conducted by CMS OMH through its contractor, NORC at the University of Chicago, pursuant to CMS’ program authority under Section 3101 of the Public Health Service Act (PHSA) to collect, maintain, and issue defined reports on demographic data as deemed appropriate regarding health disparities.

CMS Office of Minority Health: https://www.cms.gov/About-CMS/Agency-Information/OMH
MBECS submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202107-0938-016 Click View Supporting Statement for technical documentation and proposed core questionnaire  
CMS webpage with MBECS submission: https://www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-10701
FR notice inviting public comment to OMB -- see item #1: https://www.federalregister.gov/documents/2021/07/29/2021-16200/agency-information-collection-activities-submission-for-omb-review-comment-request

Point of contact: Luis Pons Perez 410-786-8557 omh@cms.hhs.gov

For AEA members wishing to submit comments to OMB, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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