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New health quality measurement standards for insurance plans offered on health insurance exchanges should be aligned with existing quality standards to reduce administrative burdens among providers and confusion among consumers, provider groups said in recent comments submitted to the Centers for Medicare & Medicaid Services.
The comments responded to a request for information issued by CMS in November (CMS-9962-NC) that sought recommendations on ways to align quality reporting and display requirements for qualified health plans offered on the exchanges (226 HCDR, 11/26/12). The new requirements, which are being developed in phases by CMS, would begin to take effect in 2016.
Section 1311 of the Affordable Care Act requires the Department of Health and Human Services to develop and administer a quality rating system for health plans offered on the exchanges and a system for surveying enrollee satisfaction. This information will be posted on the state-based exchanges--online insurance plan marketplaces--to help consumers choose among the plans when the exchanges begin offering insurance plans in October.
In comments submitted to CMS, hospital groups recommended that quality measures selected for use in the exchanges be aligned with existing federal health program quality standards, such as those developed by the National Quality Forum, a public-private standards-setting organization.
“NQF-endorsed quality measures are reviewed by multi-stakeholder committees using rigorous evaluation criteria,” noted the American Hospital Association. “Endorsed measures produce reliable and valid results, are usable for accountability programs, and are feasible to collect and report.”
The NQF is spearheading the National Quality Strategy, an initiative required by ACA and aimed at improving “the delivery of health care services, patient health outcomes, and population health.” The National Quality Strategy's goal is “to build a national consensus on how to measure quality so that stakeholders can align their efforts for maximum results,” according to the CMS information request.
Echoing AHA, the Federation of American Hospitals commented, “the National Quality Strategy should be the basis of quality reporting priorities for the exchange marketplace.”
FAH also emphasized that cost and quality information about insurance plans offered on the exchanges should be available to employers as well as consumers. “Helping employers understand the provider price and utilization factors that underlie premiums, in a manner that would not undermine marketplace dynamics that drive provider and insurer negotiations regarding price, can help them choose and/or drive the design of insurance products that better align consumers and employers in cost containment efforts,” FAH wrote.
The Children's Hospital Association pointed out that, compared with health programs for adults, there is a “lack of a robust set of measures appropriate for assessing the quality of care provided to children.” As a result, CHA recommended using a different set of quality measures for children.
Specifically, the association noted that other standards may be more appropriate for children, including standards set in the Pediatric Quality Measures Program established through the Children's Health Insurance Program Reauthorization Act, as well as those included in California's Medi-Cal (Medicaid), CHIP, and Healthy Families programs.
Representing the insurance industry, America's Health Insurance Plans (AHIP) also emphasized the importance of aligning quality standards on the exchanges with those established under the National Quality Strategy.
“These common approaches should be used across all three exchange models including the state-based exchanges, state-partnership exchanges and the [federally facilitated exchanges] to ensure meaningful comparison between health plans regardless of exchange type,” AHIP said in its comments.
Also among groups commenting was the American Medical Association, representing physicians, which also advocated “a national core set of quality measures.” However, AMA noted, “the diversity of health care services provided in the ambulatory care setting makes the adoption of one national core set of quality measures, across all payers, very challenging.”
As a result, AMA said it supports “the use of care domains to provide guidance on identifying a starter set of quality measures for the ambulatory setting, including care coordination, preventive health, patient safety, and population health-focused domains.” These are the same domains that are outlined in the National Quality Strategy, AMA noted.
AHA's comments are at http://op.bna.com/hl.nsf/r?Open=shad-93eklv. FAH's comments are at http://www.fah.org/fahCMS/Documents/On%20The%20Record/Public%20Comments/2012/CMS_Comment_Ltr_exchange-healthcare_quality_RFI.pdf. AHIP's comments are at http://op.bna.com/hl.nsf/r?Open=shad-93dktv. AMA's comments are at http://op.bna.com/hl.nsf/r?Open=shad-93dll8.
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