Minnesota Hospital Association

Policy & Advocacy

rules, regulations and comments

The Minnesota Hospital Association continually monitors state and federal rules and regulations to keep members informed and advocates on behalf of members regarding the impact of regulations on the state’s hospitals and health systems. MHA submits comment letters to share recommendations and feedback with the appropriate government organizations and health care stakeholders. Examples of rules and regulations that MHA addresses include those implementing federal or state health care reform efforts, changing payment methodologies, establishing community benefit or other standards for tax-exempt organizations, or modifying government oversight of health care activities.

June 22, 2012

Proposed Rule on Essential Health Benefit Standards & Accreditation of Qualified Health Plans

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