• Letter or Testimony
  • December 26, 2012

Health Care Quality for Exchanges RFI Comment Letter

CHA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the questions posed in the Request for Information regarding Health Care Quality for Exchanges.

CHA believes that it is imperative that measurement of and reporting on health care quality address all of the patient populations included in the Exchange. There are major opportunities to improve the health and the delivery of health care to children across the United States. Quality measurement provides the tool to assess current care by identifying and closing gaps.

Quality measures must be available and balanced across all of the priority areas outlined in the National Quality Strategy in order to provide robust information to support decision-making. For pediatrics, this means that important efforts to address the gap in pediatric measures be continued and expanded, including measures that address the needs of children with special health care needs and complex conditions.

Children’s health care presents distinctive challenges for quality measurement. All efforts to measure quality should take into account the unique features of child health and health care and should recognize the importance of pediatric development, dependency, demographics and disparities. Those who develop and use pediatric measures should address the differential epidemiology in children as compared with adults and incorporate patient and family participation in their development and implementation efforts. Measures of patient/family experience with care should be prominent and carry substantial weight. In addition, non-condition-specific measures are needed (e.g., coordination of care for children with special health care needs) because of the relatively small numbers of children with any single condition.

The Pediatric Quality Measurement Program (PQMP) established through the Children’s Health Insurance Program Reauthorization Act (CHIPRA) is the first significant national investment in pediatric quality measurement, and it has made considerable strides forward through identification of the Initial Core Measure Set and through its current efforts to develop additional measures on critically important areas through the PQMP Centers of Excellence, six of which are housed within children’s hospitals. Measures used to monitor and report on quality within the insurance marketplace should draw upon this resource, and funding of the PQMP must be continued following the expiration of the CHIPRA provisions.

Association contact: Aimee Ossman, (202) 753-5333