Comments on the Centers for Medicare & Medicaid Services Request for Information Regarding Health Care Quality for Exchanges

With the strong public concern about the cost of health insurance and health care, quality and safety concerns can be overlooked in implementation of the Affordable Care Act (ACA). Yet, the law recognizes that as a nation we must not simply cut costs or improve access, but also ensure high quality care - “Patient Protection” is embodied in the title of the ACA, after all. The Exchanges are the key new platform from which to launch the National Quality Strategy and to drive strong, meaningful quality measurement across all markets and industry actors—plans, hospitals, ambulatory surgery centers, physicians and other providers. Moreover, the Exchanges can help drive reduction of racial, ethnic and other disparities that continue to plague our health care system. While there will be variability among the states, a baseline should be developed to establish a minimum standard for each state with regard to quality and safety measurement. States would be allowed to go beyond that minimum standard, which should take into account the issues raised below.