HealthLawProf Blog

Editor: Katharine Van Tassel
Akron Univ. School of Law

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Wednesday, November 28, 2012

More on ACA Implementation

Last week, I posted on the NPRM concerning ACA standards for wellness programs, and promised more postings on federal activities implementing ACA in weeks to come.  I plan to blog about the proposed rules for essential health benefits and for market reforms banning pre-existing condition exclusions in subsequent weeks.  Today, I want to call readers' attention to an important request for information that appeared in yesterday's Federal Register on quality management in affordable insurance exchanges.  This RFI has a 30-day time window:  comments must be submitted by December 27, 2012.

As plans compete on coverage and costs, quality must not fall through the cracks.  ACA places some quality requirements on insurers offering qualified health plans in the exchange marketplace.  These include implementation of quality improvement strategies, contracting requirements to enhance patient safety, and public reporting of quality data. ACA also requires HHS to develop systems for rating care quality and enrollee satisfaction, information that is to be made available for consumers.  Finally, ACA requires HHS to develop a methodology to calculate value in a health plan.

The RFI seeks information about current practices in the following areas:

    --the current landscape of quality improvement strategies, especially those used to improve health outcomes, prevent hospital readmissions, improve patient safety and reduce errors, implement wellness and health promotion, and reduce health disparities

    --the challenges to measuring and reporting quality improvement over time

    --current public reporting and transparency efforts

    --monitoring currently used by health insurance plans to monitor provider and hospital performance

The RFI also seeks information about the applicability of quality improvement measures to the health insurance exchange marketplace.  Among other matters, it specifically requests comments about how exchanges might evaluate quality across plans, promote data collection and transparency, and develop strategies for meeting anticipated methodological challenges with public reporting of quality data.  It also seeks input about priority areas for quality rating in exchanges, such as delivery of preventive services.  Finally, the RFI seeks input about the factors HHS should consider in designing an approach to measure the value of plans that would be meaningful to consumers.

It seems likely that readers of this blog might have something to say about these critical issues regarding quality and transparency.  I do hope this RFI, with its 30-day comment period, doesn't get lost in the press of the end of the semester, finals, and the holidays.

[LPF]

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