Regulatory momentum is building around person-centered outcomes. NCQA’s proposed Person-Centered Outcome (PCO) measures for HEDIS MY 2027 aim to improve the quality of care for Special Needs Plans (SNPs), but operational realities make implementation challenging for many health plans.

Advent Advisory recently submitted public comments expressing concerns about including the proposed PCO measures at this time. While the intent aligns with improving member outcomes, current industry workflows and systems may not yet be equipped to fully support these requirements.

Key Challenges Facing Health Plans

1. State-Mandated Tools Vary Widely
   Many states require plans to use their own assessment and goal-setting forms. These forms often do not include standardized instruments or allow for Goal Attainment Scaling (GAS).
   
   
2. Data Limitations
   Information is frequently captured in unstructured fields—or even on paper—making it difficult to collect the specific data elements NCQA proposes.
   
   
3. Workflow and System Gaps
   Care management systems are generally not configured to track or report against the new PCO measure specifications. Significant system changes and staff training would be required to comply.
   
   
4. Operational Burden
   Plans may be able to meet the intent of the measures but would face a high operational lift to adhere fully to the technical requirements.

Implications for Health Plans

• Plans need to carefully assess their current care management workflows and data capabilities.
• Incremental process changes and system enhancements may be required before full adoption is feasible.
• Staff training and governance around standardized assessments will be critical to ensure compliance and defensibility.

What Plans Should Consider Now

Even before these measures are finalized, proactive steps can help plans prepare:

• Evaluate current assessment tools and goal-setting processes.
• Identify gaps in structured data capture and reporting capabilities.
• Explore hybrid or phased implementation strategies.
• Engage advisors to anticipate potential operational and regulatory impacts.

The proposed PCO measures have the potential to significantly enhance member outcomes, but operational readiness is a key barrier for many SNPs. Plans that assess their workflows, systems, and data infrastructure now will be better positioned to adopt these measures in the future.