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. We recommend CMS establish outcome measures that satisfy two simple rules:
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:
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.
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