It has suggested the CMS consider including additional measures such as tracking the number of physicians in its network that are engaged in value-based purchasing programs.
“The addition of such measures will drive reporting balance and fairness in the (quality rating system ) by recognizing variation in health plans' models … and the degree to which those models allow plans to directly or indirectly influence care delivery and patient outcomes measures,” WellPoint said in comments.
Adjusting quality ratings for socio-economic status should not be allowed “because it may signal an expectation, even acceptance, of lower outcomes for financially disadvantaged consumers,” Kaiser Permanente said in its comments.
The CMS should not start evaluating plan quality until 2016, at the earliest, because many of the proposed measures require more than a single year of data to either identify the population, assess compliance, or both, according to America's Health Insurance Plans. For example, multiple years of data are needed to determine compliance with a colorectal cancer screening measure outlined by the agency.
The quality rating system should align with other measurement systems in place that access healthcare quality, the American Hospital Association said in its comments. Even though quality standards outlined by the CMS only evaluate health plans and not providers, hospitals and physicians may need to allocate resources to collect and report measures to plans for them to meet their reporting requirements, the trade group said.
“At a time when healthcare resources are under intense scrutiny, an aligned, focused approach to quality reporting can lessen data collection burden and unnecessary duplication of efforts,” it commented.
Employers want both doctors and plans to be evaluated in an effort to ensure the full treatment experiences of patients are recorded, according to The National Business Group on Health, which represents nearly 400 companies that provide health benefits and other health programs to more than 55 million people.
The information should be easy to acquire and track because most health plans already measure and report provider quality, it contended.
Patient advocates, such as healthcare advocacy group Families USA, expressed concern that there weren't many measures that address issues of cultural competency, such as bilingual representative or enrollment forms, and accommodation of people with disabilities by both providers in plans and the plans themselves. Such measurements are needed to ensure equality of care across demographics, the group argued.
Follow Virgil Dickson on Twitter: @MHvdickson
