Alert: Comments Due on Essential Benefits (12/06) and CMS' Innocations/ACOs (12/03)
Written by John Weeks
Alert: Comments Due on Essential Health Benefits (12/06) and CMS "Innovations"/Accountable Care Organizations (12/03)
Summary: Readers
inform that 2 additional comment deadlines are coming up on key health
reform developments. Of most importance: What are processes in
clarifying the "Essential Health Benefits" package under the new law?
Will this reflect the non-discrimination language in Section 2706? Will
historic, discriminatory practices prevail? The IOM seeks comment for
this study requested by US Health & Human Services. Then, for those
of you who wish to get integrative practice/medicine/CAM into thinking
on Medicare "innovation" and Accountable Care Organizations (ACO),
a comment period on preliminary standards for ACOs ends December 3, 2010. Here
is summary background on each of these and information about how and
where to respond.
The dream of a fully-staffed lobbying arm to continuously participate in
policy-setting was never so present: 3
comment deadlines cluster together for the coming December 3-6 weekend.
Readers recently informed me of the first two reported below. I then send a reminder of the Integrator Alert on integrative health care in the Nation's Prevention Strategy sent
November 15, 2010. Hopefully some of you will find time to respond and these agencies will hear from a few people from these communities. (If
you like, share your comments with me and I will share them with Integrator readers.)
1. IOM's Public Input on "Determination of Essential Health Benefits"
The
Institute of Medicine (IOM) has engaged a consensus study, at the
request of the Secretary of US Department of Health and Human Services,
to "make recommendations on the criteria and methods for
determining and updating the essential health benefits package" for policies of Qualified Health Plans under the Affordable Hewalthcare Act. The IOM's notice and response information follow and can of Qualified Health Plans under the Affordable Hewalthcare Act. The IOM's notice can be directly viewed here.
"Activity Description
"The Patient Protection and Affordable Care Act (PPACA), signed into
law on March 23, 2010, will allow individuals and businesses to
purchase health insurance directly through exchanges-competitive
marketplaces where buyers can compare coverage. These exchanges will
offer a choice of qualified health plans (QHPs) that vary in coverage
levels but meet certain standards in categories of care and limits on
patient cost sharing. The PPACA stipulates that these QHPs will cover
the general categories of: ambulatory patient services; emergency
services; hospitalization; maternity and newborn care; mental health and
substance use disorder services including behavioral health treatment;
prescription drugs; rehabilitative and habilitative services and
devices; laboratory services; preventive and wellness services and
chronic disease management; and pediatric services including oral and
vision care. Further details of an "essential health benefit" package
are to be defined by the Secretary of Health and Human Services (HHS)
based on the scope of benefits offered by a typical employer plan.
"At the request of the Secretary of HHS, the IOM is undertaking a
study that will make recommendations on the criteria and methods for
determining and updating the essential health benefits package. The IOM
will not define specific service elements of the benefit package.
Instead, the IOM will review how insurers determine covered benefits and
medical necessity and will provide guidance on the policy principles
and criteria for the Secretary to take into account when examining QHPs
for appropriate balance among categories of care; the health care needs
of diverse segments of the population; and nondiscrimination based on
age, disability, or expected length of life.
"Additionally, the IOM will offer advice on criteria and a process for
periodically reviewing and updating the benefits package. To provide
public comment, please use our online form. Please submit your comments by December 6 to ensure that
your perspective and the evidence base you provide can be examined
before the committee's first meeting."
A
reader with a government position (who for that reason chose to be
anonymous) alerted me to this comment period. She wrote of her notes
below: "I think some thoughtful comments could help to at
least get IP/IH/CAM in the conversation." Here is her guidance.
"On
November 17, CMS issued a notice inviting people to submit comments by December
3 that will be used in the development of regulations on Accountable Care
Organizations (ACOs). ACOs are groups of providers that will manage and
coordinate the care of Medicare beneficiaries. If an ACO can demonstrate that
it is able to reduce Medicare costs (e.g. by decreasing hospital admissions,
emergency room use, etc.), the ACO will share in the cost savings.
"Under
the same request for information, CMS is also accepting comments on the
new Center for Medicare and Medicaid Innovation (CMMI), which was established
to test innovative payment and service delivery models that improve quality of
care and reduce costs.
"Both
the ACOs and the CMMI were established in Sections 3021 & 3022 of the Affordable Care Act to improve
quality and lower costs by creating integrated health care delivery systems
that are patient-centered and foster the participation of physicians and other
clinicians in solo or small practices.
"While
nothing here explicitly addresses Integrative Health Practitioners or
Integrative Health Care, these initiatives are simply too big and too important
to ignore. ACOs are going to want to show that they have saved Medicare
money through things such as fewer inpatient hospitalizations, ER visits,
invasive procedures, visits to high priced specialists, etc. by the
beneficiaries that are assigned to them.
Shouldn't they be able to offer
acupuncture, yoga, or any other CAM modality to patients?
Even though
most IPs would not be eligible to be part of the ACO and share directly in the
cost savings, wouldn't it be helpful if the regulations specifically allowed,
or even encouraged, the ACOs to include CAM as part of their strategy to
improve quality and reduce cost?
When the data is evaluated, wouldn't it
be interesting if the ACO with a strong CAM component was successful in
reducing costs and improving care?
Perhaps
even more critical is to submit comments on how the CMMI is defining integrated
health care delivery systems: Shouldn't they include all
licensed health professionals in the health care delivery system, not just
those currently recognized by Medicare?
If CMS wants to tests new
delivery models, shouldn't they look at some of the Integrative Clinics that
are already providing a range of both conventional and CAM services?
"This
is a rare opportunity to provide formal input on something when it is still in
its developmental stage. Even though most IPs are not Medicare
providers, the new CNNI may have more flexibility to consider innovative
approaches that improve quality of care and outcomes, and reduce overall costs,
than any previous initiatives. If nothing else, this is an opportunity to
start a dialogue and educate the new leadership at CMS that Integrative
Health is more than just conventional practitioners talking to each other, and
could be an important component of changing the way health care is delivered
and paid for."
3. Reminder: Comments on "Integrative Practitioners" in the Prevention & Wellness Strategy Due 12/5
Surgeon General Benjamin: Comments sought on draft framework
An earlier Integrator alert noted
that a comment period on the nation's emerging strategy for health
promotion, prevention and wellness ends December 5, 2010. This one is a
critical important because "integrative practice" and integrative health
care" are already inlaid in language in the Affordable Healthcare Act
that established the new Prevention and Health Promotion Strategy. Click here to directly access the Surgeon General's comment page on the subject.
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Overall Comment: This process can feel overwhelming. Consider reviewing the 3, choosing one, clicking in, and having your say. These are each significant opportunities for the innovation that is "integrative practice" to be seen and heard.Again, if you like, share your comments with me and I will share them with Integrator readers - anonymously or with attribution, your choice.
Send your comments to
for inclusion in a future Integrator.