C1. Supporting outcome-based certification, extended further

The shift from checklist certification to Streamlined Modular Certification with outcomes and metrics is an important reform, and it should be defended and extended rather than diluted. The direction of travel is right: certify investments against corresponding improvements in outcomes.

In practice, however, the outcomes have been hard to define, and certification continues to lean on system-focused measures of automation rather than true impact on residents, staff, and taxpayers. I recommend CMS establish outcome measures that satisfy two simple rules:

The measure must be able to get better or worse over time, rather than be Boolean. An evergreen measure can be tracked forever and is never done.

The measure must correspond to something that matters to a person who delivers or receives the end result. This rule automatically eliminates solution-specific measures like percentage of transactions automated. What matters to a person is less effort and better quality, not how much was automated, especially when automation creates more problems than it solves.

The best outcome measures are typically lagging in nature, with effects like population health not visible in data until long after the investment. That is not a reason to wait. Two measures satisfy both rules and could be evaluated and published in the near-term:

Administrative cost per service provided: total overhead, billing, compliance, and administrative expenditure in a period, divided by the units of service actually delivered

Cost to serve per service provided: total direct cost of delivering services in a period, divided by the units of service actually delivered

Published as trendlines, segmented by service type, these two ratios tell every stakeholder the same story: whether the enterprise is getting more service to people for each dollar spent, or just spending.

Supporting outcome-based certification, extended further

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