The Association for Community Affiliated Plans (ACAP) thanks you for providing us with an opportunity to comment on the draft regulation called Patient Protection and Affordable Care Act; Exchanges and Qualified Health Plans, Quality Rating System (QRS), Framework Measures and Methodology. This draft regulation was published November 19, 2013 in the federal register.
ACAP is an association of 57 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to approximately 10 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans for duallyeligible individuals. Nationally, ACAP plans serve roughly one-third of all Medicaid managed care enrollees. Sixteen of ACAP’s Safety Net Health Plan members have chosen to participate in the Marketplaces in 2014.
ACAP supports the use of a Quality Reporting System (QRS). We agree with the overarching goals of providing consumers with comparable and useful quality data to aid in plan selection and to facilitate regulatory oversight on issues of quality. We also agree with the four principles included in the notice. We do, however, have comments on the specifics of the QRS and appreciate your willingness to consider our comments.
Our positions are explained below: