The CMS Universal Foundation – A Blueprint for Quality Measurement

In 2022, the Centers for Medicare & Medicaid Services (CMS) launched the National Quality Strategy with the mission to "achieve optimal health and well-being for all individuals"[1]. The strategy outlines eight key goals[2]:

1. Advance health equity and whole-person care
2. Engage individuals and communities to become partners in their care
3. Achieve zero preventable harm
4. Enable a responsive and resilient healthcare system to improve quality
5. Improve quality and health outcomes across the care journey
6. Align and coordinate programs and care settings
7. Accelerate and support the transition to a digital and data-driven health care system
8. Transform health care using science, analytics and technology

CMS has many levers to improve healthcare quality, including value-based payment programs, alternative payment models, quality measurement and public reporting. To ensure ongoing alignment across the multiple quality programs and to advance the National Quality Strategy, CMS has defined a Universal Foundation[3]of quality measures.

By prioritizing the development of interoperable, digital quality measures that allow for comparisons across programs, CMS aims to reduce the burden on providers, allowing for greater focus on closing care gaps and mitigating disparities in care.

Selection criteria for the CMS Universal Foundation

CMS operates more than 20 quality programs resulting in transparent quality performance information, accountability and improvement. However, the reporting burden and potential for misalignment across programs has caused CMS to move toward a more parsimonious set of measures based on the following criteria:

• High national impact:The measure addresses significant health issues.
• Benchmarking capability: The measure can be compared nationally and globally.
• Applicability: The measure is relevant to multiple populations and settings.
• Stratification: The measure can be broken down to identify disparity gaps.
• Scientific acceptability: The measure is based on solid scientific evidence.
• Feasibility: The measure is practical and computable, or capable of becoming digital.
• No unintended consequences: The measure does not produce adverse effects.

The CMS Innovation Center will continue to test new quality measures for CMS models. As quality measurement improves or when quality goals are met, CMS will evolve the measurement set over time[4].

Key Implications for Health Plans

Approximately 70% of the Preliminary Universal Foundation measures are Healthcare Effectiveness Data and Information Set (HEDIS) measures. The National Committee for Quality Assurance's (NCQA) vision for electronic clinical data systems (ECDS) measures and digital quality measures (dQMs) aligns closely with CMS objectives for the Universal Foundation[5]. Further, the Core Quality Measures Collaborative (CQMC), a partnership between America's Health Insurance Plans (AHIP) and CMS, aims to align measures across public and private payers to achieve congruence in the use of measures for quality improvement, transparency and payment purposes[6]. There is significant overlap between the CQMC Core Measure Sets and the Universal Foundation. As health plans implement value-based care programs, selecting measures from the Universal Foundation will minimize provider burden and enable meaningful benchmarking.

The Universal Foundation is prominently mentioned in the 2025 CMS Call Letter for Medicare Advantage Plans. Social Need Screening and Intervention will be added to the 2025 display page based on the 2023 measurement year, while Depression Screening and Follow-Up for Adolescents and Adults and Adult Immunization Status will be added to the 2026 display page based on the 2024 measurement year. CMS intends to include all of the Universal Foundation measures as part of the Part C and D Star Ratings, pending future rulemaking[7].

Leveraging interoperability standards to optimize the use of clinical data for meaningful, high value measurement will be a continued emphasis for NCQA and CMS[8]. This will require health plans to collaborate with providers to procure clinical data for their members in Continuity of Care Document (CCD) or Fast Healthcare Interoperability Resources (FHIR) formats.

Advancing Health Equity

A major tenet of these programs is to advance health equity. Health plans need to evaluate their current sources of race and ethnicity, along with other data related to Social Determinants of Health (SDoH), to adequately measure health disparities and implement programs aimed at closing gaps in access and improving outcomes across populations. Social needs screening is one of the Universal Foundation measures in the domain of equity.

The Evolution the Universal Foundation

The preliminary Universal Foundation measures include 10 Adult measures and 13 Pediatric measures[9], with additional measures being evaluated as add-ons applicable to a subset of programs. The highest priority of these is for behavioral health[10], expected in 2024.

While behavioral health is critically important to whole-person care, there are many challenges to the collection of behavioral health data[11].Health plans should expect a continued focus on screening and follow-up for patients with depression, serious mental illness and substance use.

Conclusion

The CMS effort to implement consistent, nationally standardized quality measures across programs can enhance health outcomes and promote health equity. However, successful implementation requires continuous monitoring and adoption of best practices.

For Measurement Year 2024, CMS has adopted 17 NCQA HEDIS measures. If you are looking for a HEDIS vendor, we have some of the most tenured experts in the industry, with a depth and breadth of experience allowing flexibility to meet current and future needs. Download our brochure SS&C® CareAnalyzer HEDIS® Reporting for further information and reach out today to put our expertise to work for you.

[1]https://www.cms.gov/medicare/quality/meaningful-measures-initiative/cms-quality-strategy

[2] https://www.cms.gov/files/document/quality-motion-cms-national-quality-strategy.pdf

[3] https://www.cms.gov/medicare/quality/cms-national-quality-strategy/aligning-quality-measures-across-cms-universal-foundation

[4] https://www.nejm.org/doi/full/10.1056/NEJMp2215539?query=featured_home

[5] https://www.ncqa.org/wp-content/uploads/CMS-Universal-Foundation_Webinar_7-14-23_TO-SPKRS-7-13-23_ac_ecs.pdf

[6] https://p4qm.org/CQMC

[7] https://www.cms.gov/files/document/2025-announcement.pdf

[8] https://www.ncqa.org/wp-content/uploads/CMS-Universal-Foundation_Webinar_7-14-23_TO-SPKRS-7-13-23_ac_ecs.pdf

[9] https://www.cms.gov/medicare/quality/cms-national-quality-strategy/aligning-quality-measures-across-cms-universal-foundation

[10] https://www.cms.gov/files/document/2024-quality-measure-development-plan-annual-report.pdf

[11] https://www.ncqa.org/wp-content/uploads/NCQA-BehavioralHealthCareIntegration-Whitepaper-WEB.pdf

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