June 22, 2012
Submitted electronically
Commissioner Mike Rothman, Minnesota Department of Commerce
Commissioner Ed Ehlinger, Minnesota Department of Health
Commissioner Cindy Jesson, Minnesota Department of Human Services
RE: Standards related to essential health benefits and recognition of entities for the
accreditation of qualified health plans
Dear Commissioners:
On behalf of our 145 member hospitals and 17 member health systems, the Minnesota Hospital
Association (MHA) appreciates the opportunity to comment on proposed rule CMS-9965-P,
Patient Protection and Affordable Care Act; Data Collection to Support Standards Related
to Essential Health Benefits; Recognition of Entities for the Accreditation of Qualified
Health Plans.
MHA supports the proposed rule for collecting data from the identified health plans for defining
essential health benefits. Under the proposed language, section 156.20 (2), each plan will be
required to submit all health benefits in the plan, treatment limitations, drug coverage, and
enrollment. MHA agrees with this list.
MHA generally agrees with the proposed approach in certifying qualified health plans to operate
in the Health Insurance Exchange. The preamble of the proposed rule identifies those categories
required by the Affordable Care Act: clinical quality measures such as the Healthcare
Effectiveness Data and Information Set (HEDIS); patient experience ratings on a standardized
Consumer Assessment of Health Care Providers and Systems (CAHPS) survey; consumer
access; utilization management; quality assurance; provider credentialing; complaints and
appeals; network adequacy and access; and patient information programs. MHA supports using
these criteria, and particularly stresses the importance of ensuring provider network adequacy in
certifying qualified health plans for the Exchange.
MHA also agrees with the proposed additional clinical quality measures in section
156.275(2)(ii), particularly the proposal to include a measure set that “spans a breadth of
conditions and domains,” including mental health and substance abuse disorders. MHA also
supports B-E of the proposed clinical quality measures.
While MHA agrees with these measures for accrediting qualified health plans, the association
also suggests the next phase of accreditation include clinical measures such as those from
Minnesota Community Measurement, which measure the health of patients, not just what care
patients have received. Consumers will find that sort of information more helpful as they use the
Exchange to compare cost and quality data for health plans and providers.
Thank you again for the opportunity to comment. If you have any questions, please feel free to
contact me at (651) 659-1405 or [email protected].
Sincerely,
Jennifer McNertney
Policy Analyst
Minnesota Hospital Association