The Association for Community Affiliated Plans (ACAP) thanks you for providing us with an opportunity to comment on the Draft Report for Comment, Measure Applications Partnership: 2014 Report from the Dual Eligible Beneficiaries Workgroup. ACAP is an association of 58 nonprofit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to over 12 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans and MedicareMedicaid Plans for dually-eligible individuals.
ACAP thanks the NQF for its leadership with the overall Measure Applications Partnership and especially for its efforts to develop performance measures, public reporting, and payment programs for the Medicare-Medicaid dual eligible population. We appreciate your willingness to consider our comments. ACAP developed our comments quickly after consultations with our member health plans, and our comments reflect those discussions.
The series of reports form the Duals Eligibles Workgroup have been helpful. We appreciated the update to the Family of Measures and, as in previous comments, urge parsimony as new measures are considered. We support your exclusion of measures deemed to be too narrow as narrow measures can lead to an unwarranted and counter-productive proliferation of measures.
We are concerned that reporting requirements for the Medicare-Medicaid Plans (MMP) under the duals financial alignment demonstration have (necessarily) begun before this development work is complete.
Appendix D is very clear about which level of analysis is appropriate for each measure. It would be helpful to have an explanation in the body of the report which points out that not all measures may be applied to health plans. Some measures may apply only to clinicians, facilities and delivery systems and some are population based.
We have identified several specific areas of the draft report where we have suggestions, questions and/or comments.