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Comments/Letters

August 21, 2017
Consumers and Purchasers Urge CMS to Reconsider Provisions that Compromise the Availability of Public Performance Information 
Seventeen consumer and purchaser organizations signed-on to C-P Alliance's comment letter, expressing significant concerns that the proposed rule compromises the availability of performance information for the public and will not prepare clinicians for the inevitable transition toward a value-driven health care system. Our main comments include the following recommendations:  

  • CMS should retain the low-volume threshold from the first program year to maintain the original intent of MIPS to assess and reward clinicians based on their performance relative to their peers;
  • CMS should establish a more meaningful pathway for clinicians to become familiar with MIPS by increasing the MIPS performance threshold and assigning the MIPS cost performance category a 10% category weight; and
  • CMS should move as quickly as possible away from the pick-your-measures approach in the MIPS quality performance category, as this menu approach compromises CMS's ability to both identify topped out measures that should be removed from MIPS and to evaluate meaningful quality improvement by clinicians. 

 

June 14, 2017
Consumers and Purchasers Advocate for High-Value Measures in CMS's Hospital Accountability Programs  
Twenty consumer and purchaser organizations signed-on to C-P Alliance's comment letter, urging CMS to adopt only high-value measures - that is, those that are meaningful, important, and actionable - in its hospital accountability programs including the Hospital Inpatient Quality Reporting Program (IQR), the Hospital Value-Based Purchasing Program (HVBP), the Hospital-Acquired Condition Reduction Program (HACR), the Hospital Readmissions Reduction Program (HRRP), and the PPS-Exempt Cancer Hospital Quality Reporting Program (PCHQR). We caution CMS against making any changes to these programs to reduce burden without considering the trade-offs in availability of information.

Our comments also focused on the approach to and appropriateness of risk-adjustment for social risk factors: (1) We support CMS's work to establish peer groups among participating hospitals for the purpose of payment, in accordance with 21st Century Cures Act; (2) We oppose risk-adjustment for social factors in the calculation of performance measures, as this will mask disparities in care and outcomes across vulnerable populations; and (3) We strongly oppose risk-adjustment for social factors in patient safety measures and payment programs focused on reducing patient harm, like the HACR.

Please find the Hospital (IPPS) proposed rule here, and read our comments to CMS here

 

April 19, 2017
C-P Alliance Comments on CMS's Interim Final Rule for the Comprehensive Joint Replacement and Episode Payment Model Programs 
In response to CMS's interim final rule which proposes to delay the effective date of the Comprehensive Joint Replacement (CJR) and Episode Payment Model (EPM) programs, C-P Alliance expressed concern that any broader delays to the CJR and EPM programs would impede our momentum for moving from volume- to value-based payment. We encouraged CMS to use the proposed delay to further strengthen the programs' designs and offered the following specific recommendations: 

  • Incorporate additional high-value patient-reported outcomes, such as global health surveys;
  • Allow for multiple treatment options to support comprehensive, multi-disciplinary patient-centered evaluations; and
  • Use a prospective negotiated rate to allow providers to employ/experiment with services that do not generate a fee-for-service claim.

Please find our full comment letter here

 

October 3, 2016
C-P Alliance Comments on CMS's Proposed Rule, Advancing Care Through Episode Payment Models, Which Expands CMMI's Mandatory Episode-based Payment Models to Cardiac Care
The Consumer-Purchaser Alliance supports CMMI's expansion of mandatory episode-based payment models beyond the Comprehensive Care for Joint Replacement (CJR) models for hip and knee replacements to AMI, CABG, and hip and femur fractures. C-P Alliance's comment letter to CMS focuses primarily on strengthening the dashboard of quality measures, which will ultimately improve the Episode Payment Models (EPMs) for cardiac care to better serve consumers and purchasers. To be successful, episode-based payment models must include quality measures that evaluate the most meaningful areas of care for consumers and purchasers. Without appropriate quality measures and other consumer protections, incentives to reduce costs may contribute to stinting on care. 
Our specific recommendations urge CMS to:

  • Expand the dashboard of measures to include measures of the most frequent and egregious complications;
  • Add a PROs reporting option and provide financial incentives to providers, separate from the EPM's quality composite, for reporting PRO data; and
  • Include, in future models, elements that support and facilitate patient engagement and shared care planning. 

 

September 6, 2016
C-P Alliance Comments on the Physician Fee Schedule CY 2017, Specifically Focusing on Strengthening the Medicare Shared Savings Program (MSSP)
The Physician Fee Schedule CY 2017 proposed rule contains a wide range of programs and provisions that are important to consumers and purchasers, updating physician payment policies, payment rates, and quality provisions for services provided in calendar year 2017. C-P Alliance submitted comments to CMS, focusing on strengthening the set of performance measures and ensuring that the MSSP ultimately serves the needs of consumers and purchasers.

Our comments to CMS on strengthening the MSSP measure set specifically advocate for:

  • Inclusion of NQF #0729, Optimal Diabetes Care- a composite measure that includes blood pressure control as a component;
  • Adoption of NQF #2483, Gains in Patient Activation Measure Scores at 12 Months, as a pay-for-reporting measure; and
  • Continued committment to high-value measures, as CMS demonstrated in the NPRM's inclusion of ACO-44 (Use of Imaging Studies for Lower Back Pain), ACO-37 (Risk-Standardized Acute Admission Rates for Patients With Heart Failure), and ACO-38 (Risk-Standardized Acute Admission Rates for Patients With Multiple Chronic Conditions). 

 

June 27, 2016
C-P Alliance Comments on the MACRA Proposed Rule: Establish Core Sets of High-Value Measures for MIPS and Require MultiStakeholder Feedback on APM Program Design Components
26 organizations sign on to C-P Alliance’s comments to CMS on the MACRA proposed rule. The proposed rule lays out how the landmark bill, MACRA, will be implemented: the specific requirements for the new Merit-Based Incentive Payment System (MIPS), and the specific incentives for physicians to participate in certain Alternative Payment Models (APMs). 

Ensuring that physician value-based purchasing meets the needs of consumers and purchasers is a critical piece of our advocacy agenda. Overall, we applaud CMS for its leadership in moving physician payment away from solely fee-for-service and support the direction of CMS's proposed implementation of MACRA in rewarding high performance and improvement. Our comments focus on a few key areas:

  • Establishing core sets of high-value measures by specialty or subspecialty, to enable direct comparisons of similar providers using a consistent set of important quality indicators;
  • Placing greater weight on the collection of patient-reported outcomes (PROs) as a component of the Clinical Practice Improvement Activity (CPIA) performance category, as this is a unique opportunity to break through existing barriers to developing PRO measures;
  • Requiring that there be multistakeholder feedback on APM program design components, particularly quality measures, and that measure innovation be a key feature of program requirements for most Advanced APMs; and 
  • Using Intermediate APM models' quality provisions to calculate a quality performance score, to ensure better overall comparability with both MIPS providers and Advanced APMs.
 
 
March 1, 2016
C-P Alliance Recommends Emphasis on PROMs & Patient Input to Measure Development
21 organizations signed on to support C-P Alliance’s comments to CMS on the inaugural draft Measure Development Plan.  As you may recall, in April of 2015, President Obama signed the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) into law, forging a new path for physician payment. The Measure Development Plan supports new clinician payment programs by serving as a strategic framework for the future of clinician quality measure development, highlighting known measurement and performance gaps, and recommending approaches to close these gaps.

Our comments to CMS make specific recommendations, including 1) the systematic development of an infrastructure for collecting and reporting patient-reported outcomes (PROs), as a step towards developing patient-reported outcome measures (PROMs) for widespread use; 2) Implementation of an electronic short form patient experience survey; and 3) Expansion of the avenues in which patients can provide input to the measure development process.      

 
December 15, 2015
C-P Alliance joins Consumer Partnership for eHealth in strong stand for Meaningful Use
In response to the final rule for Stage 3 of the Meaningful Use program, C-P Alliance joined CPeH and others to emphasize the role of health IT in enabling truly person-centered care and in the capture and reporting of the information we need to make health care decisions. Health IT, and the Meaningful Use requirements, will play a critical role in broader health system transformation and interoperability. Read our comments here
 
 
November 17, 2015
C-P Alliance recommends high standards for new Medicare physician payment programs
In response to a request for information from CMS, C-P Alliance recommended setting a high bar for the new Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) tracks for Medicare physician payment. In our comments, we urge CMS to prioritize a handful of high-value, cross-cutting measures that are meaningful to consumers and purchasers; to leverage the new Clinical Practice Improvement Activities to spread the use of patient-reported outcome tools and measures; and to ensure that any bonus payments tied to APM participation are linked to true improvment in patient experience, quality, and efficiency.
 
 
September 8, 2015
Consumers and Purchasers applaud progress and push for faster improvements to Medicare physician payment and accountability programs
17 organizations signed on to support C-P Alliance's comments to CMS on the CY 2016 proposed rule for the Medicare Physician Fee Schedule. The rule includes a wide range of programs and provisions that support improved patient care and greater transparency for provider performance, including improved payment for primary care services, removing low-value measures and improving reporting requirements for the Physician Quality Reporting System (PQRS), adding new information and benchmarks to Physician Compare, and more. Our comments made specific recommendations for improving these programs, such as suggesting measures to ensure services are leading to better health and better value, and reporting individual clinician-level performance information whenever possible, particularly for measures of patient experience.
 
C-P Alliance encourages CMS to raise the bar for quality performance and patient-reported outcomes in new payment model
In response to CMS's proposal to establish a mandatory bundled payment for lower extremity joint replacement, C-P Alliance raised concerns about a low bar for quality performance and unrealistic expectations for the collection of patient-reported outcomes (PROs). The Comprehensive Care for Joint Replacement model proposal includes a payment incentive for the collection of PROs; while we agree that PROs are an excellent way to ensure care is addressing patients' priorities, the required rates of reporting to earn payment incentives are much higher than rates seen in existing programs. In our comments, we encourage CMS to start with a lower threshold and raise the bar over time.
 
 
June 16, 2015
Consumers and Purchasers advocate for continued improvements to Federal Inpatient Quality and Reporting programs
17 organizations signed on to support C-P Alliance’s comments to CMS on the FY 2015 proposed rule for the Inpatient Prospective Payment System. The rule includes a wide range of programs and provisions that support improved patient care, including the Hospital Readmissions Reduction Program, the Hospital Inpatient Quality Reporting (IQR) Program, the Electronic Health Record "Meaningful Use" Incentive Program, and more. Our comments made specific recommendations for filling measure gaps for three important safety and efficiency programs. We urged CMS to ensure publicly reported information is robust and presented in a way that is meaningful and actionable for consumers and purchasers.
 
 
June 15, 2015
C-P Alliance and Consumer Partnership for eHealth urge CMS to keep patient engagement requirements in Meaningful Use program
In a letter jointly organized by C-P Alliance and the Consumer Partnership for eHealth, 50 organizations joined voices to express their disappointment with the proposal from CMS to reverse key patient engagement criteria in the Meaningful Use program for 2015-2017. The comments warn that reducing the requirements for health care providers to show that their patients used online access to view, download, or transmit health records will undermine and thwart progress on patient and family engagement. Read our comments opposing the CMS proposal here.
 
 
May 29, 2015
C-P Alliance offers comments on two proposed rules for Meaningful Use of Health IT program
CMS and ONC released proposed rules for Stage 3 of the Meaningful Use incentive program and for the 2015 Edition certification criteria for health IT. These rules reflect an evolving technology landscape and make progress toward a health care system that utilizes various forms of health IT, not just EHR technology. The proposals include important steps to make patient-generated health data more central to an individual's health record and to improve individuals' ability to communicate effectively with their entire care team. Consumer-Purchaser Alliance responded to these proposals in two comment letters supported by 16 consumer and purchser organizations, emphasizing the role of health IT in enabling truly person-centered care and in the capture and reporting of the information we need to make health care decisions. Read our comments on the Stage 3 CMS rule here, and our comments on the 2015 Edition Certification criteria here.
 
 
April 3, 2015
Shared Nationwide Interoperability Roadmap lays out critical steps for public and private sector stakeholders to advance interoperable health IT infrastructure
The Office of the National Coordinator for Health Information Technology put forward a draft Roadmap identifying critical functions and action steps to achieve nationwide interoperability. Consumer-Purchaser Alliance responded to the draft Roadmap in this comment letter (please follow link) supported by 12 consumer and purchaser organizations, emphasizing our vision for meaningful interoperability as the key to care coordination across the continuum, and to the ability to measure outcomes over time and across settings.
 
 
February 6, 2015
ACO proposed rule allows greater flexibility to encourage increased participation 
CMS released a proposed rule on the Medicare Shared Savings Program (MSSP) for ACOs in December, 2014.  This is the first time in three years that the program is being updated through rulemaking.  To date, the MSSP includes more than 330 ACOs and 4.9 million beneficiaries.  On February 6, Consumer-Purchaser Alliance submitted a set of comments (please follow link) supported by 13 consumer and purchaser organizations to CMS, focusing on the following key issues:
  • Payment that Drives Care Delivery Transformation
  • Care that Supports Patient Engagement
  • Quality Measures that Drive Meaningful Accountability and Improvement
  • Public-Private Alignment that Spreads Overall System Transformation

Federal HIT Strategic Plan is headed in the right direction
Led by the Office of the National Coordinator for Health Information Technology, the federal government proposed a federal strategic plan that identifies the government’s priorities for health IT and describes specific federal goals, objectives, and strategies to achieve the vision of health information  that is accessible when and where it is needed to improve and protect people’s health and well-being.

The Consumer-Purchaser Alliance developed a letter (please follow link) responding to the proposed plan and received sign-on from 12 consumers and purchaser organizations.  The letter applauds the vision, mission, and principles laid out in the strategic plan, but suggests some specific changes, such as:

  • Adopting a transformational and disruptive approach to push the boundaries of a system that has been slow to change
  • Fully embracing a person-centered paradigm
  • Bringing consumers and purchasers to the table in every major area
  • Closely linking strategies and metrics to the outcomes of the triple aim: better health, better experience of care, and lower costs
 
December 22, 2014
CMS makes steady progress in Medicare physician value purchasing programs
Every summer CMS releases proposed rules on their physician payment programs and C-P Alliance organizes a response from our participants.  This year, we had 25 consumer and purchaser organizations sign on to the letter.  C-P Alliance has reviewed the final rules by CMS.  Noteworthy changes include applying the value-based payment modifier to all physicians and doubling the incentive (2% to 4%), the application of a financial penalty for non-participation in PQRS, the establishment of a payment for non face-to-face chronic care management services, and the first change in ACO measures in three years.  We are disappointed that many low-value process measures were retained in PQRS and concerned that these measures allow some specialists to earn credit for participation without providing information of value to consumers and purchasers.  At the same time, we applaud CMS for implementing a new requirement to report from a cross-cutting measure set that applies to all physicians who see patients in face-to-face encounters.  Click here for a table that provides more details on what was included in the final rule.
 
November 24, 2014
Medicare inpatient programs outperform ambulatory programs in advancing value purchasing 
Every year CMS releases proposed rules on their hospital inpatient and outpatient Medicare programs and C-P Alliance organizes a response from our participants.  This year, we had 33 unique consumer and purchaser organizations sign on to the inpatient and outpatient letters.  The response from CMS in the final rules indicates that the consumer and purchaser voices have been heard.  As a result, programs for both settings of care are increasingly moving toward the public reporting of robust outcome measures.  The inpatient setting in particular has made great strides in tying more meaningful measures to payment for value-based purchasing. Click here to find an analysis of how our comments matched up to CMS' final rules.
 
 
July 21, 2014
Consumers and Purchasers Oppose Delay of EHR Incentive Program
In response to the CMS proposed rule to delay implementation of Meaningful Use Stage 3 by one year and make other changes to the Electronic Health Record (EHR) Incentive Program, CP Alliance urged CMS and ONC to maintain the current schedule to ensure that consumers and purchasers can realize the full potential of much-needed advancements in health IT. The Meaningful Use and EHR Incentive Programs are foundational to ensuring that we have the health information technology infrastructure to meet the needs of health reform. Meaningful Use is inextricably tied to ongoing efforts to transform the health care delivery system to meet the National Quality Strategy goals of better outcomes, improved individual experiences of care, and reduced costs. If the proposed changes were to go into effect, providers and hospitals experiencing difficulties in obtaining 2014 Edition Certified EHR Technology (CEHRT) would be allowed to use 2011 Edition CEHRT to quality for incentive payments in 2014. Because 2011 Edition technology was only built to support Stage 1, any providers or hospitals using 2011 Edition technology in 2014 will not be able to perform critical Stage 2 functions such as secure messaging between patients and providers; offering patients the ability to view, download, and transmit their own health information; and improving care transitions with a summary of care record for transitions and referrals. Our comments oppose the program delays and call attention to the fact that, once again, consumers and purchasers would have to wait to realize many of the benefits of health IT, particularly the patient engagement and interoperability criteria finalized for Stage 2.
 
 
June 30, 2014
Consumers and Purchasers Advocate for Continued Alignment  and Advancement across Federal Inpatient Quality and Reporting Programs
26 consumer, labor and employer organizations signed on to support C-P Alliance’s comments to CMS on the FY 2015 proposed rule for the Inpatient Prospective Payment System. The rule includes a wide range of programs and provisions that support improved patient care, including the Hospital Readmissions Reduction Program, the Hospital Inpatient Quality Reporting (IQR) Program, the Electronic Health Record "Meaningful Use Incentive Program, and more. Our comments conveyed  support for CMS’ proposed inclusion of common high-value measures across multiple programs, while emphasizing opportunities to address program gaps through the swift implementation of NQF-endorsed outcome measures, as well as the advancement of measure development and electronic reporting systems. In addition, C-P Alliance provided specific recommendations regarding the expansion of the Hospital-Acquired Condition and Readmissions Reduction Programs, which in their early stages have demonstrated the capacity of performance-based payment to drive improvement. 
 
 
January 21, 2014
CP Alliance Provides Comments to CMS on Proposed Quality Rating System in Health Insurance Marketplaces
In its response to a proposed rule on the Quality Rating System (QRS) for health plans in the new health insurance marketplaces, the CP Alliance urged CMS to provide accessible and meaningful information to consumers and purchasers to facilitate choice, care improvement, and payment reform. The CP Alliance recommended several changes to improve the clarity, detail, and usefulness of information provided to consumers; emphasized the importance that such information has in facilitating value-based purchasing by employers and the exchanges themselves; and noted the critical need to include provider performance measures in the QRS within two years.
 
 
September 6, 2013

CP Alliance Asks CMS to Strengthen Medicare Physician Fee Schedule Programs

In its response to the CMS proposed rule on the Payment Policies under the Physician Fee Schedule (PFS), CP Alliance is urged the Medicare program to strengthen its efforts to improve the quality of physician care for the nation's 47 million Medicare beneficiaries. In a letter to CMS, 27 consumer, labor, and purchaser organizations emphasized the need for CMS to address measure gaps in areas of critical importance, such as clinical and patient-reported outcomes, appropriateness, and resource use. The organizations expressed support the CMS proposal to require physicians and other clinicians to report more measures to create a better picture of the quality of care they provide but also expressed disapproval of the over-reliance on discrete process measures that are not linked to outcomes in the Physician Quality Reporting System (PQRS). CP Alliance expressed enthusiastic support for the public reporting patient experience measures on Physician Compare and encouraged CMS to post the information it has already gathered as quickly as possible.

 

 

September 6, 2013

Consumers and Purchasers Ask CMS to Continue to Improve the Medicare Hospital Outpatient and Ambulatory Surgery Center Quality Reporting Programs
In a letter to CMS, 29 consumer, labor, and employer organizations expressed support for the effort made in this year's Outpatient Prospective Payment System (OPPS) proposed rule to align the Outpatient and Ambulatory Surgery Center Quality Reporting Programs (OQR and ASCQR respectively). The organizations, however, express their concern over the proposed removal of a measure of whether patients discharged from the emergency department receive a transition record. The letter also offers recommendations on additional areas in which the organizations would like to see measures developed and implemented in the outpatient and ambulatory surgical center settings, including patient experience and patient-reported outcomes, patient safety, diabetes, and depression.

 

 

August 27, 2013

CP Alliance Offers Support for CMS Approach to Collecting Information on Consumer Purchasing Experience in the Health Exchange Marketplace

In response to a request from CMS for feedback on two draft survey tools designed to collect information from consumers purchasing health insurance through the new Health Insurance Exchange (“Marketplaces”) program, CP Alliance submitted its comments with the support of 19 signatories. Building on CP Alliance’s initial input to CMS in 2012, which focused on priority topics and questions for consideration in the development of these survey tools, this year’s letter is largely supportive and offers key recommendations regarding the importance of assessing issues related to shared-decision making, self-care management, health status/functional status, and patient experience.

 

 

June 25, 2013

Consumers and Purchasers Advocate for Rapid Implementation of Key Outcome and Patient Safety Measures for Hospital Quality and Reporting Programs

25 consumer, labor and employer organizations signed on to support CP Alliance’s comments to CMS on the FY 2014 proposed rule for the Inpatient Prospective Payment System. The rule includes a wide range of programs that are important to consumers, labor organizations and employers, particularly the new Healthcare-Acquired Conditions (HAC) Reduction Program. The comments conveyed strong support for CMS’ proposal for the future direction of a number of hospital quality and reporting programs. In addition, CP Alliance provided specific input on several critical outcome measures that should be added to these programs, urging CMS not to delay the opportunity to maximize accountability and transparency through payment and public reporting.

 

May 6, 2013
CP Alliance Calls for More Meaningful Health Insurance Exchange Navigator Standards
CP Alliance submitted comments to CMS in response to the proposed rule for implementing the Health Insurance Exchange Standards for Navigators and Non-Navigator Assistance Personnel. In the letter, which includes the support of 21 consumer and purchaser organizations, CP Alliance makes recommendations regarding the inclusion of quality data in the Navigator certification standards and training modules. CP Alliance also comments on the need for strong oversight of provider organizations that become certified Navigators, and the need for all Navigators, whether or not they are funded with Federal grant money, to be held to the same certification and training standards.

 

April 22, 2013
CP Alliance Calls for Expansion of Health Information Exchange
CP Alliance responds to a CMS RFI (Request for Information) on accelerating and expanding health information exchange across providers, titled Advancing Interoperability and Health Information Exchange (HIE) (CMS 0038-NC). In the letter, we voiced strong support and provided recommendations for advancing interoperability and health information exchange, particularly around infrastructure, measurement, and incentives.

 

April 8, 2013
CP Alliance Calls for Registries to Serve Consumer and Purchaser Interests
CP Alliance responds to a CMS RFI (Request for Information) on using clinical quality measures (CQMs) for eligible professionals reported under the Physician Quality Reporting System (PQRS), Electronic Health Record (EHR) Incentive Program (Meaningful Use), and Other Reporting Programs. (CMS 3276-NC). In particular, CMS is considering the use of these in PQRS and Meaningful Use. In the letter to CMS, we make recommendations on how registries in federally-sponsored accountability programs should be used to ensure that they meet the needs of consumers and purchasers.

 

March 26, 2013
CP Alliance Calls for Strengthened Patient Experience Tools
CP Alliance responded to a RFI (Request for Information) to aid in the design and development of a survey regarding patient experiences with hospital outpatient surgery departments/ambulatory surgery centers and patient‐reported outcomes from surgeries and procedures performed in these settings. (CMS 4171-NC) fIn a letter to CMS, 29 consumer and purchaser organizations strongly supported CMS' efforts to improve these measures in these settings and offered suggestions, such as particular concepts to measure and methods for leveraging HIT in data collection.

 

January 14, 2013
CP Alliance Calls for Renewed Efforts in Meaningful Use Stage 3
CP Alliance responded to a RFC from the Health Information Technology Policy Committee (HITPC), urging it to work with ONC and CMS to accelerate the trajectory of the Meaningful Use Program, in its third stage, with a focus on the kinds of rigorous requirements that drive true transformation. In a letter to the HITPC, 25 consumer, labor, and purchaser organizations advocated strongly for (1) Information sharing; (2) Patient and family engagement; and (3) Using HIT to improve quality and reduce costs. (pdf Re: Request for comments by the HIT Policy Committee regarding the Stage 3 definition of
Meaningful Use of EHRs.)

CP Alliance Calls for Strong Quality and Cost Reporting in Health Insurance Exchanges (now "Marketplaces")
CP Alliance responded to a RFI on quality reporting in the Exchanges with a letter to CCIIO, signed by 24 consumer and purchaser organizations. The comments advocated strongly for having meaningful quality reporting available to consumers beginning in October 2013, arguing that public reporting of quality and cost information are integral to the program's success. The comments also included examples of national and state reporting sites that should be viewed as models for how to provide transparent performance information. (pdf RE: CMS-9962-NC: RFI Regarding Health Plan Quality Management in Affordable Insurance Exchanges)

 

September 5, 2012
CP Alliance Calls for More Robust Medicare Physician Fee Schedule Programs
CP Alliance is urging the Medicare program to strengthen its efforts to improve the quality of physician care for the nation's 47 million Medicare beneficiaries. In a letter to CMS, 28 consumer, labor, and purchaser organizations said stronger quality measurement and public reporting programs are essential to creating a system of care that rewards better care, higher value, and more coordination of care instead of the volume of services provided. (pdf RE: Response to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2013 Proposed Rule (CMS-1590-P))

 

September 4, 2012
Consumers and Purchasers Ask CMS to Make the Medicare Hospital Outpatient and Ambulatory Surgery Center Quality Reporting Programs More Meaningful
In a letter to CMS, 27 consumer, labor, and employer organizations expressed their concern that there was little effort made in this year's Outpatient Prospective Payment System (OPPS) proposed rule to expand and improve upon the Outpatient and Ambulatory Surgery Center Quality Reporting Programs (OQR and ASCQR respectively). The organizations provided CMS with suggested measures that would support the recommendations made by the Measure Applications Partnership (MAP), including additional clinician-based measures as well as measures related to supporting better health in communities, making care more affordable, and person- and family-centered care. (pdf RE: Hospital Outpatient Prospective and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Electronic Reporting Pilot: Comments from National Consumer, Labor, and Employer Organizations)

 

July 20, 2012
CP Alliance Responds to Request for Information on the Development of a Consumer Experience Evaluation Tool with Qualified Health Plans (QHPs) and Exchanges
Well-informed design and implementation of standardized consumer experience tools will assist Americans in selecting providers and treatment. In response to CCIIO's RFI, CP Alliance submitted this letter with suggestions on the survey scope and timing. (pdf RE: CMS-9963-NC: Request for Domains, Instruments, and Measures for Development of a Standardized Instrument for Use in Public Reporting of Enrollee Satisfaction with their Qualified Health Plan and Exchange)

 

June 25, 2012
CP Alliance Comments on Proposed Rule for the Medicare Inpatient Prospective Payment System (IPPS)
Enhancements to the Inpatient Quality Reporting (IQR) program will integrate quality metrics to identify and drive better health, better care, and lower costs. Although generally in support of the overall direction of the proposed rule, CP Alliance submitted this comment letter urging increased alignment with other purchasers' value-based efforts. In addition, CP Alliance supported the measures proposed by CMS while cautioning against the wholesale removal of granular patient safety information. (pdf RE: CMS-1588-P: Proposed Changes to the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and FY 2013 Rates and to the Long Term Care Hospital PPS; Quality Reporting Requirements for Specific Providers and for Ambulatory Surgical Centers)

 

June 18, 2012
CP Alliance comments on Federally Facilitated Exchanges (FFE) General Guidance Document
Due to the significant number of states that are unlikely to have a state Exchange established by the deadline, it is likely that an FFE will be established in a significant number of states to ensure that all Americans have access to a marketplace for purchasing affordable, comprehensive individual health coverage. The CP Alliance submitted this letter, urging HHS and CCIIO to strengthen the language in the FFE guidance to ensure that meaningful quality and cost information will be made available to consumers in time for the FY 2014 start date. (pdf RE: Comments on “General Guidance on Federally Facilitated Exchanges”)

 

May 7, 2012
Consumers and Purchasers Weigh In On Meaningful Use
Twenty-six consumer and purchaser organizations praised CMS for moving Meaningful Use in the right direction in a letter to the agency and a press release. They also called on CMS to maximize health information exchange, and rapidly develop high value quality measures and build them into the program. (pdfs RE: Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 2 (CMS-0044-P); Consumer and Purchaser Organizations Commend CMS Plan for Meaningful Use, Call for More Progress)

 

April 12, 2012
CP Alliance Urges Department of Health and Human Services to Set High Standards for Hospital Patient Safety Measures
With the annual rulemaking cycle for Medicare Hospital programs set to begin shortly, CP Alliance wrote this letter to HHS, urging it to set the highest possible standards for public reporting and accountability related to hospital patient safety measures. In this letter, CP Alliance provided examples of measures that are essential to support its efforts to provide meaningful information to consumers, purchasers, and providers. (pdf letter to The Honorable Secretary Kathleen Sebelius)

 

March and April, 2012
CP Alliance Comments on a Variety of NCQA Programs
The National Committee for Quality Assurance (NCQA) recently closed a comment period for their Physician and Hospital Quality Update. CP Alliance submitted comments that were overall supportive with some suggested modifications. NCQA also solicited comments on their proposed update to the NCQA Accreditation and Certification Process. In its comments, CP Alliance pointed to the opportunity for NCQA to align with federal quality reporting requirements for qualified health plans operating in the Exchanges. Finally, NCQA solicited feedback on their proposed Technical Specifications for ACO Measures. CP Alliance submitted comments that called for more innovation in the measure dashboard and reporting at the provider level (in addition to aggregate ACO). (pdfs 2012 Physician and Hospital Quality update; Consumer-Purchaser Disclosure Comments: NCQA 2013 Accreditation and Certification Products Update; Technical Specifications for ACO Measures)

 

March 29, 2012
CP Alliance Meaningful Use Strategy Session
CP Alliance held a strategy session to highlight gains and opportunities for improvement in the Meaningful Use (Stage 2) proposed rule. We expect opposition to some of the gains and strongly encourage consumers and purchasers to voice their opinions. The session's recording
and slides are available for download. (pdf CP Alliance Strategy Session on Stage 2 Meaningful Use)

 

January 13, 2012
CP Alliance weighs in on Medicare Advantage Quality Bonus Payment
In this letter, CP Alliance responded to CMS’s RFC, encouraging the agency to leverage the Medicare Advantage (MA) Quality Bonus Payment (QBP) demonstration to fulfill Congress's intent for MA plans: to operate more efficiently than traditional Medicare without sacrificing quality. CP Alliance advocated for meaningful measures and reporting, including those focusing on mortality, readmissions, and patient safety. (pdf letters to Cynthia Tudor, Ph.D., Director, Medicare Drug Benefit and C&D Data Group; All Medicare Advantage Organizations, Prescription Drug Plan Sponsors, and Other Interested Parties)

 

October 31, 2011
Consumers and Purchasers Comment on Proposed Rules for New Health Insurance Exchanges
CP Alliance submitted this comment letter to CMS with 23 co-signatures from partner organizations, in response to HHS’s proposed rule developing guidance to states as they develop Health Insurance Exchanges (later “Marketplaces”) for individuals and small businesses. The comments urge the inclusion of strong quality, cost, and value information as well as consumer and purchaser representation on governance boards and a framework for a strong marketplace for small businesses (called Small Business Health Options Program (SHOP) exchanges). In addition to the comment letter, CP Alliance held an information webinar on the topic of Exchanges, based on the comments being submitted. For just the slides from this webinar, click here. (pdfs RE: Patient Protection and Affordable Care Act; Establishment of Exchanges and Qualified Health Plans; Patient Protection and Affordable Care Act; Establishment of Exchanges and Qualified Health Plans)

 

August 30, 2011
Consumers and Purchasers Commend Proposed New Rules Affecting Quality of Care Delivered in the Medicare Outpatient and Ambulatory Surgical Center Settings, and the Hospital Value-Based Purchasing Program
In a letter to the Centers for Medicare & Medicaid Services (CMS), 28 consumer, labor, and employer organizations voiced their strong support for proposed regulations to outpatient and ambulatory surgery center quality reporting programs. The organizations expressed support for measures on patient safety, outcomes, and diabetes care. For the new Hospital Value-Based Purchasing Program, organizations strongly supported CMS' proposal to make outcome measures count for 30 percent of hospitals' total scores and reducing the weight given to clinical process measures. The proposed rule can be found here. (pdfs RE: Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment; Ambulatory Surgical Center Payment; Hospital Value-Based Purchasing Program: Comments from National Consumer, Labor, and Employer Organizations; Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment; Ambulatory Surgical Center Payment; Hospital Value-Based Purchasing Program; Physician Self- Referral; and Provider Agreement Regulations on Patient Notification Requirements)

 

August 30, 2011
CP Alliance advocates for CMS to set higher standards for how physicians are rewarded and evaluated
In a letter to the Centers for Medicare & Medicaid Services (CMS), 29 consumer, labor, and purchaser organizations urged the agency to strengthen the proposed Physician Fee Schedule (PFS) by being bolder in paying physicians for value and assessing performance. They recognized the agency's recent strides in both areas and call for changes that will have a significant and lasting impact on bending the cost curve and improving quality. (pdf RE: Response to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2012 Proposed Rule (CMS-1524-P))

 

August 8, 2011
Consumers and Purchasers Commend Release of Medicare Data for Performance Reports and Call for Broad Availability
Thirty-eight consumer and purchaser organizations voiced their strong support for CMS releasing Medicare Data for performance reporting. The organizations called for permitting the broadest possible use allowed under the law to achieve the greatest public benefit, while protecting patient privacy and data security, and also recommended making the data more affordable, especially for non-profit organizations. On September 20, 2011, the Wall Street Journal published an opinion piece from PBGH Medical Director Arnold Milstein and CP Alliance member Robert Krughoff, along with George Shultz echoing CP Alliance's August comment. (pdfs RE: Availability of Medicare Data for Performance Measurement, More Transparency, Better Health Care)

 

June 20, 2011
Consumers and Purchasers Commend Proposed Changes to the Medicare Inpatient Hospital Reporting Program That Will Lead to Improvements in Patient Safety
On June 20, 2011, 30 consumer, labor, and employer organizations voiced their strong support for CMS' proposed changes to the Medicare Inpatient Quality Reporting Program (IQR), reflecting the agency's continued efforts to foster increased transparency and promote a market that recognizes and rewards quality rather than volume. The comments focus primarily on including the proposed hospital-acquired infection (HAI) measures related to surgical site infections, MRSA, c-diff, and ventilator-associated infections, as well as support for proposed clinical measures and the measure of spending per beneficiary. The proposed rule can be found here. (pdf RE: CMS-1518-P: Proposed Changes to the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and FY 2012 Rates and to the Long Term Care Hospital PPS and FY 2012 Rates)

 

June 6, 2011
Consumers and Purchasers Applaud Proposed Rules for Medicare Shared Savings Program and Provide Recommendations for Monitoring Anticompetitive Behavior
CP Alliance – with 25 signatories – applauded CMS' proposed rule on Medicare Shared Savings Program for ACOs and urged the agency to take further steps to ensure that ACOs provide health care that is patient-centered, high quality and affordable. CP Alliance also urged CMS to include additional provisions to keep the health care marketplace competitive. One week prior, CP Alliance sent a letter with 22 signatories to the Federal Trade Commission (FTC) and the Department of Justice (DOJ) in response to their proposed antitrust guidelines for ACOs. (pdfs RE: Response to Medicare Shared Savings Program: Accountable Care Organizations (ACOs) Proposed Rule; letter to Federal Trade Commission Office of the Secretary)

 

April 12, 2011
Consumers and Purchasers Support HHS' Commitment to Improving Patient Safety
CP Alliance issued a strong statement of support for HHS’s new initiative, titled Partnership for Patients, and applauds HHS's commitment to improving patient safety and addressing both the significant need to prevent harm, and to improve care transitions for patients moving across different settings of care. More information on the initiative can be found here. (pdf Consumers and Purchasers Applaud HHS’ Partnership for Patients National Initiative Will Improve Hospital Care and Lower Costs)

 

March 21, 2011
The National Quality Strategy, Charting a Unified Course for Improving Health Care Quality
CDPD is pleased to see that the comments it submitted in October 2010 on the draft National Quality Strategy are reflected in this first plan. This plan is an important step towards a unified quality strategy. CP Alliance looks forward to continued collaboration with the Administration in further refining the strategy and developing concrete goals. CP Alliance's statement on the NQS is available here. (pdfs RE: National Health Care Quality Strategy and Plan; National Strategy for Quality Improvement in Health Care; Consumers and Purchasers Welcome the Nation’s First National Quality Strategy for Improving Health and Health Care)

 

March 18, 2011
CP Alliance Comments on CMS' Proposal to Curb Payment for Preventable Care-Related Conditions
In a letter to CMS, CP Alliance supported CMS' proposal to expand the current Medicare Hospital Acquired Conditions (HAC) non-payment program to include provider-preventable conditions (PPCs) and health care acquired conditions (HCACs) in the Medicaid program. In addition to supporting the proposed non-payment events, CP Alliance recommended additional conditions and measures for the program, improving the public reporting framework, and ensuring that payment methodology does not impede access to care. (pdfs CMS-2400-P: Medicaid Program: Payment Adjustment for Provider-Preventable Conditions Including Health Care Acquired Conditions; Medicaid Program; Payment Adjustment for Provider-Preventable Conditions Including Health Care- Acquired Conditions)

 

March 8, 2011
Basing Medicare Hospital Payment on Performance
Twenty-eight consumers and purchasers voiced their strong support of CMS' proposal to begin tying Medicare hospital payments to how well hospitals care for their patients. They encouraged CMS to reward hospitals for high levels of performance, give greater weight to patient experience in determining payments, focus on measures that are meaningful to consumers and purchasers, and set an aggressive timetable for increasing the amount of payment that is based on performance. (pdf RE: 42 CFR Parts 422 and 480: Medicare Program Hospital Inpatient Value-Based Purchasing Program Proposed Rule)

 

March 3, 2011
Promoting Measurement of How Providers Care for Their Medicaid Patients
CP Alliance provided feedback to the Agency for Healthcare Research and Quality (AHRQ) on the set of measures that the agency proposed recommending states use to assess how well providers care for adults enrolled in Medicaid. This is an important step forward in the Medicaid program, where public accountability is sorely lacking, particularly in the adults-under-65 years of age segment. CP Alliance made recommendations on focusing on a parsimonious set of high-value measures to promote use and impact. (pdf CMS-2420-NC: Medicaid Program: Initial Core Set of Health Quality Measures for Medicaid-Eligible Adults)

 

February 25, 2011
Moving Meaningful Use Forward to the Next Stage
In a letter to the Office of the National Coordinator, 27 consumer, purchaser, and labor organizations commended the HIT Policy Committee (HITPC) on the draft definition for Stage 2 of the Meaningful Use incentive program. The draft definition sets the bar high enough to achieve meaningful results, while at the same time be reasonably met by providers. The 27 organizations were supportive in particular of the focus on getting providers to demonstrate significant functional capabilities, increasing the number of patients that will be given access to their health information, and improving care coordination. They also provided specific suggestions and examples for how the draft definition can be bolstered to better support consumer and provider decision-making. (pdf RE: Request for Comments on Draft Definition of Meaningful Use Stage 2)

 

February 25, 2011
Comments to CMS on Transforming the Physician Quality Reporting System
In a letter to CMS, twenty-eight consumer, labor, and purchaser organizations advocated for CMS to make rapid and significant changes to the Physician Quality Reporting System (PQRS). PQRS is a program that pays clinicians for submitting data on quality measures. In the future some of the quality measures will be used in Physician Compare and potentially for performance-based payment. Unfortunately, in its current form, PQRS fails to serve the public interest. The organizations called for the program to require clinicians to report on more and better measures, focus on whether care made a difference for the patient, make data available to the private sector, and ensure that beneficiary needs and interests are primary. (pdf RE: 2012 Physician Quality Reporting System Town Hall Meeting Comments)

 

January 14, 2011
CP Alliance Comments on Proposed Quality of Care Measures Delivered Through Medicaid and the Children's Health Insurance Program (CHIP)
In a letter responding to the Agency for Healthcare Research and Quality (AHRQ)'s RFC, CP Alliance supported the addition of some measures while urging the Agency to focus on measures that provide information on health outcomes. CP Alliance also identified existing core set measures that would benefit from refinement and suggested topics for pursuit of measure development. (pdfs RE: Priority Setting for CHIPRA Pediatric Quality Measures Program; Priority Setting for the Children’s Health Insurance Program Reauthorization Act (CHIPRA) Pediatric Quality Measures Program)

 

December 3, 2010
Weighing in on CMS' Implementation of ACOs
CP Alliance submitted a comment letter in response to questions posed by the Centers for Medicare & Medicaid Services on Accountable Care Organizations (ACOs). CP Alliance advocated for ACOs to be evaluated on a core set quality and cost measures. We also recommended CMS work in partnership with the private sector to result in greater change. (pdf RE: Request for Information Regarding Accountable Care Organizations (ACOs) and the Medicare Shared Saving Program)

 

November 30, 2010
Comments to CMS on Implementing the Physician Compare Website
Thirty-four consumer, labor, and purchaser organizations urged the Centers for Medicare & Medicaid Services (CMS) to put consumers first in its development of the Affordable Care Act mandated Physician Compare website. In a letter to the agency, they conveyed the importance of reporting performance information at the level of the individual physician, providing meaningful comparisons of physicians, and fostering the growth of all-payer databases to support both Physician Compare and private sector reporting initiatives. (pdf RE: Implementation of the Physician Compare Website Comments from National Consumer, Labor, and Employer Organizations)

 

November 19, 2010
Setting Standards for Accountable Care Organizations (ACOs)
CP Alliance commented on NCQA's proposed ACO Criteria for 2011. If done right, ACOs could increase quality and affordability of care. We encouraged NCQA to strengthen its standards around performance measurement and cost containment to help assure these aims are achieved. (pdf RE: Comments on NCQA’s Accountable Care Organizations (ACO) Draft 2011 Criteria)

 

October 15, 2010
Building a Comprehensive National Health Care Quality Strategy and Plan
In a comment letter to HHS, 27 consumer, labor, and employer organizations applauded the agency's proposed National Health Care Quality Strategy and Plan. At the same time, the signators provided guidance on how the Strategy can be strengthened, by clarifying the framework around which the strategy is built, including specific targets for improvement (both aspirational and short-term), emphasizing the need for cost containment, and generally reflecting priorities and tactics that are central to high-value care. The Strategy will play an important role in guiding the public and private sectors in their efforts to improve health care quality across the nation. In accordance with the Affordable Care Act, HHS will finalize the Strategy and deliver it to Congress by January 2011. (pdf RE: National Health Care Quality Strategy and Plan)

 

October 4, 2010
Comments to HHS on Health Insurance Exchanges
In accordance with the Affordable Care Act, Americans will be able to purchase coverage through national and state health insurance Exchanges starting in 2014. In response to the Department of Health and Human Service's request for input on how Exchanges should be implemented, CP Alliance, in its comment letter, urged the federal government and states to require that Exchanges be "active purchasers." As active purchasers, Exchanges would not only expand coverage but serve as vehicles for transforming the delivery system and lowering health care costs. (pdf RE: Planning and Establishment of State-Level Exchanges; Request for Comments Regarding Exchange-Related Provisions in Title I of the Patient Protection and Affordable Care Act Comments from National Consumer, Labor, and Employer Organizations)

 

September 27, 2010
Releasing Medicare Data for Performance Reporting
The availability of Medicare data for performance measurement is key to achieving a system that uses value to inform decisions about care and payment, both in the public and private sector. It is a public good that should be shared broadly with qualified entities, as long as protections of patient privacy and data security are in place, and there should be flexibility to promote innovative measurement activities. Read more in our comment letter to CMS on how we think this piece of the Affordable Care Act should be implemented. (pdf RE: Implementation of Section 10332 of the Patient Protection and Affordable Care Act, Availability of Medicare Data for Performance Measurement)

 

August 31, 2010
Comments on CMS' proposed changes to the Hospital Outpatient Prospective Payment System
In a comment letter to CMS, 27 consumer, labor, and employer organizations supported the agency's plans to improve quality reporting in the hospital outpatient setting. Over the course of the next few years, CMS expects to expand the number of measures being reported by hospital outpatient facilities with a focus on many areas that are important to consumers and purchasers (e.g., overuse, efficiency, care coordination and transitions). CP Alliance also developed a backgrounder on the proposed changes. (pdfs RE: Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2011 Payment Rates: Comments from National Consumer, Labor, and Employer Organizations; Medicare Outpatient Prospective Payment System: Hospital Outpatient Program Quality Data Reporting Program (HOP QDRP) Proposed Rule for FY 2011: Background on Consumer, Labor and Employer Comments)

 

August 24, 2010
Comments to CMS on Medicare Physician Payment for 2011
Twenty-four consumer, labor, and employer organizations urged CMS to take bolder strides in transforming physician payment. They underscored the need to rapidly develop robust foundations for value-based purchasing -- effective measurement, data collection, and reporting. They also emphasized the importance of reforming how physician services are valued so they reflect the perspectives of patients and society as a whole. Read comments. (pdf RE: CMS Proposed 2011 Physician Fee Schedule Comments from National Consumer, Labor, and Employer Organizations)

 

July 2, 2010
Setting Standards for Medical Homes
CP Alliance commented on NCQA's proposed Patient-Centered Medical Home Standards for 2011, which serve as a standardized tool for assessing whether physician practices have the systems and processes in place needed to support a patient-centered medical home (PCMH). Our comments appreciate the significant progress NCQA has made in enhancing its standards, but also underscore the importance of improving them to make patient experience and meaning use "must pass" elements to receive recognition for having the capabilities of a PCMH. (pdf RE: Comments on NCQA’s Patient-Centered Medical Home 2011 Draft Standards)

 

July 2010
"Meaningful Use" Criteria Will Be Meaningful
Purchasers and consumers have a right to expect that the federal tax dollars used for health IT adoption will lead to significant improvements in health care quality and provider accountability. The inclusion of pharmacy, imaging and lab orders in electronic records can improve patient safety and reduce duplication by automatically by applying evidence-based rules and care alerts. Click here for more information on the final rules for the first stage of meaningful use. CP Alliance held a briefing on the how the final rules align with the perspectives of consumers and purchasers, and what the next steps for meaningful use will entail. (pdf Meaningful Use of Health IT Meaningful Use of Health IT What Will Stage I Mean for Consumers and Purchasers)

 

June 18 , 2010
Expanding Hospital Quality Measurement and Public Reporting: Comments to CMS on Proposed Changes to the Inpatient Prospective Payment System Proposed Rule
In response to proposed changes to the IPPS Proposed Rule's pay-for-reporting program (often referred to as "Reporting Hospital Quality Data for Annual Payment Update," or RHQDAPU) for 2012 - 2014, 30 consumer, labor union, and employer organizations affirmed their support for an expanded set of required quality measures. In addition to commenting on the measures being proposed, the comments addressed a range of important issues, including criteria for removing measures from the program, and the addition of measures that rely on registry data, which until now have not been included in RHQDAPU. Read Comments. (pdf RE: Comments on Changes to the Reporting of Hospital Quality Data for Annual Hospital Payment Update (RHQDAPU) Program)

 

June 17, 2010
Creating a Framework for Improving Care for Individuals with Multiple Chronic Conditions
HHS released a draft Strategic Framework on Multiple Chronic Conditions to support a coordinated vision and plan of action on how to improve care for individuals with multiple chronic conditions. CP Alliance provided comments applauding HHS' efforts to create a framework to address the unique needs experienced by this population. The comments also expressed the need to strengthen the framework by maximizing the contributions of health information technology and performance measures. (pdf RE: HHS Strategic Framework on Multiple Chronic Conditions Comments on Behalf of Consumer, Labor, and Employer Organizations)

 

June 4, 2010
Implementing Health Care Reform: Developing an Insurance Web Portal to Inform Coverage Decisions
The Affordable Care Act requires HHS to develop a "Web Portal" to assist individuals and small businesses identify affordable health insurance coverage in any state. CP Alliance submitted comments on HHS' interim final rule on the Web Portal, emphasizing the importance of designing this tool to help users factor in quality and value of care (of health plans and individual providers) into their decisions about what coverage best reflects their needs. (pdf RE: HHS Interim Final Rule on Implementing a Web Portal Comments on Behalf of Consumer, Labor, and Employer Organizations)

 

March 1, 2010
Improving Quality Measurement in Medicaid and the Children's Health Insurance Program (CHIP)
CP Alliance submitted comments to the Agency for Healthcare Research and Quality (AHRQ), responding to their Initial Core Set of Children’s Healthcare Quality Measures for Voluntary Use by Medicaid and CHIP Programs. In our comments, we mostly praised the proposed set and provided suggestions for an additional measure, as well as suggestions spurring implementation of these measures by the states. (pdf Re: Comments on Initial Core Set of Children’s Healthcare Quality Measures for Voluntary Use by Medicaid and CHIP Programs)

 

March 15, 2010
Meaningful Use of Health Information Technology
CP Alliance submits comments to CMS on March 15 in response to a notice of proposed rulemaking, supported by 21 consumer, labor union, and employer organizations, applauding the direction of CMS' meaningful use requirements as well as providing suggestions for how the requirements could be further strengthened. (pdf RE: Comments on the Proposed Rule for Incentive Payments to Providers, as per the American Recovery and Reinvestment Act of 2009)

 

August 31, 2009
Comments on CMS' Proposed Changes to the Medicare Physician Fee Schedule and PQRI Program
CP Alliance submits comments to CMS in response to proposed changes to the Physician Fee Schedule and PQRI program, supported by 23 consumer, labor, and purchaser organizations. These comments reflect concerns that CMS' proposed payment changes to the PFS for 2010 were not deep or wide enough to promote the transformation of the health care system into one that incents high-quality, high-value and patient-centered care. (pdf RE: CMS Proposed 2010 Physician Fee Schedule Comments from National Consumer, Labor, and Employer Organizations)

 

August 31, 2009
Comments on CMS' Proposed Changes to the Outpatient Prospective Payment System Rules
CP Alliance submits comments in response to CMS' proposed changes to the OPPS rule for CY 2010, supported by 17 consumer, labor, and purchaser organizations, regarding the direction that they would like to see the Hospital Outpatient Program Quality Data Reporting Program take. (pdf RE: CMS Proposed 2010 Physician Fee Schedule Comments from National Consumer, Labor, and Employer Organizations)

 

June 30, 2009
Comments on CMS' Proposed Changes to the Inpatient Prospective Payment System Rules
In response to CMS' proposed changes to the IPPS rule for 2011, 23 consumer, labor, and purchaser organizations submitted these comments, affirming their support for four additional quality measures to be added to the Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) program, as well as reiterating their concern that CMS focus on adding measures related to health care outcomes and other measures that are meaningful to consumers and purchasers. (pdf RE: Comments on Changes to the Reporting of Hospital Quality Data for Annual Hospital Payment Update (RHQDAPU) Program)

 

May 15, 2009
Comments on Senate Finance Committee Delivery System Reform Options
The Senate Finance Committee released a report on Transforming the Health Care Delivery System: Proposals to Improve Patient Care and Reduce Health Care Costs, the first in their three-part series on reform. CP Alliance submitted a letter strongly supporting the direction of reforms that were outlined, provided recommendations on the policy options, and identified some cross-cutting areas that were not addressed in the report. (pdfs Transforming the Health Care Delivery System: Proposals to Improve Patient Care and Reduce Health Care Costs; Re: Comments on Senate Finance Committee Policy Options for Transforming the Health Care Delivery System)

 

December 16, 2008
Comments on Plan to Transition to a Medicare Value-Based Purchasing Program for Physician and Other Professional Services
In these comments, twenty consumer, labor, and purchaser organizations affirmed the goals, objectives, and assumptions outlined in the Issue Paper developed by CMS. The organizations also strongly requested that CMS actively coordinate and align with private sector initiatives and provided suggestions in the areas of measurement, incentives, data, and public reporting.

 

June 13, 2008
Comments on CMS' Proposed Changes to the Inpatient Prospective Payment System Rules
In these comments in response to CMS' proposed changes to the IPPS rule, twenty-five consumer, labor, and purchaser organizations have affirmed their support for 9 additional Hospital Acquired Conditions (HACs) to which non-payment policies would apply, as well as an additional 43 quality measures to be implemented by FY 2011. CP Alliance also commented on a number of other data collection issues, as well as issues related to CMS' Medicare Hospital Value-Based Purchasing Program.

 

March 5, 2008
Comments on CMS' Report to Congress, Plan to Implement a Medicare Hospital Value-Based Purchasing Program
In these comments in response to CMS' Report Plan to Implement a Medicare Hospital Value-Based Purchasing Program that was delivered to Congress in late-2007, thirty-one consumer, labor, and purchaser organizations affirmed their support for hospital pay-for-performance and it being one component of more substantial payment reform. Under the Deficit Reduction Act of 2005, CMS was required to submit a report to Congress on developing a plan for hospital value based purchasing. Implementing the plan, however, requires further action from Congress.

 

August 31, 2007
Comments on Medicare's 2008 Physician Payment Policies
In this letter, thirty-one consumer, labor, and purchaser organizations affirmed Medicare's Physician Quality Reporting Initiative (PQRI) as one part of wide-ranging efforts needed to reform how providers are paid and held accountable and provides comments on strengthening the program.

 

June 12, 2007
Comments on Medicare's 2008 Hospital Reporting and Payment Policies
In this letter, twenty-four consumer, labor, and purchaser organizations support Medicare's efforts to ensure that hospitals are financially penalized for providing poor quality care and urge CMS to rapidly incorporate additional performance measures for public reporting.

 

April 19, 2007
Consumer, Labor and Purchaser Comment on Medicare's Hospital Value-Based Purchasing Plan
In this letter, more than 20 consumer, labor and purchaser organizations provided extensive feedback on Medicare's Hospital VBP Program. Current Medicare payment policies reward the delivery of quantity, not quality, of care. Value-based purchasing, which links payment more directly to performance, is a key strategy that CMS is adopting in order to evolve from being a passive payer to an active purchaser of care.

 

January 24, 2007
Plan to Implement Medicare Hospital Value-Based Purchasing
In this letter to CMS, 17 consumer, labor, and purchaser organizations provided feedback on CMS's plan to implement Medicare Hospital Value-Based Purchasing.

 

October 10, 2006
Hospital Inpatient and Outpatient Payment Changes
In this letter to CMS, CP Alliance provided feedback on changes to the Hospital Inpatient and Outpatient Payment program.

 

August 21, 2006
Comments on Medicare Physician Payment
In a letter to CMS, 27 consumer, labor, and purchaser organizations provided feedback to CMS on the Medicare Physician Payment program.

 

June 22, 2006
Consumers, Labor, and Purchasers Affirm June 12 Comments to Secretary Leavitt
In a letter to HHS and CMS, 16 consumer, labor, and purchaser organizations provided feedback on public reporting and value payment programs along with Hospital Quality Reporting, Value-Based Purchasing, and the Health Care Information Transparency Initiative.

 

January 18, 2005
Development and Adoption of a National Health Information Network
In a letter to the Office of the National Coordinator Health Information Technology, CP Alliance commented on how widespread interoperability of health information technology (HIT) and health information exchange (HIE) can be achieved.

 

January 17, 2005
HCAHPS - Hospital Patient Experience Survey
In a letter to CMS, CP Alliance provided input on the development and implementation of Hospital Consumer Assessment of Health Plans Survey (Hospital CAHPS).

 

 



 


 


 



 

  • expand the dashboard of measures to include measures of the most frequent and egregious complications;
    • add a PROs reporting option and provide financial incentives to providers, separate from the EPM's quality composite, for reporting PRO data; and
    • to include, in future models, elements that support and facilitate patient engagement and shared care planning.
      • to continue its commitment to outcome measures, both clinical and patient reported, and to replace process measures with outcome measures for the MSSP reporting requirements;
      • to adopt a continually greater focus on measures of patient and caregiver experience, care coordination, and patient-reported outcomes; 
      • to align the MSSP reporting requirements for ACO-11 with that of the Quality Payment Program's CEHRT criterion for Advanced APMs, by requiring at least 50% of eligible clinicians billing through the TIN of an ACO participant to successfully report on ACO-11; and
      • to strengthen its proposal to allow voluntary beneficiary attestation by providing linguistically and culturally appropriate materials to help consumers understand what the ACO model is, how the model of payment and care functions, what attestation means to them, and what their rights are with respect to accessing care from other providers.