CT independent consumer advocates have published comments on SIM’s first 4 policy papers.
Regarding Issue Brief #1
(provider surveys), advocates urge that the results of consumer experience of care surveys should be made public to use as tools for choosing care and as a lever to improve care quality, SIM must ensure that results of surveys are used constructively within practices to address gaps, and SIM should provide practices with low scores assistance to improve patient experience of care.
Regarding Issue Brief #2
(payment), advocates are very concerned with proposed options #b and c which would seriously undermine the quality goals of SIM by assuring no payment to providers for care coordination and other important care management services beyond 18 months, despite strong evidence that these value-added services significantly improve the quality and efficiency of care, regardless of whether shared savings are produced. Advocates believe that services that promise to improve value, whether traditional treatments such as drugs or new, innovative services such as care management, should be treated equally.
Regarding Issue Brief # 3
(glade path administration), advocates are very concerned both with the consolidation of administration and standard-setting under one very new state agency, and with the assumption underlying that proposal: that the successful patient-centered medical homes model based on NCQA accreditation, performing very well in CT’s Medicaid program and generally accepted throughout the US health care delivery system as the appropriate certification standard, should be abandoned in favor of some new, CT-specific, yet-to-be developed standard. There is a large body of evidence that NCQA accredited PCMHs are associated with improved health outcomes and there is a growing list of almost 1000 certified PCMHs in CT currently. If advanced standards are necessary, although there is no evidence they are, CT should follow the lead of a few other states by requiring those standards in addition to NCQA certification. CT should build on what is working, not dismantle it.
Regarding Issue Brief # 4 (community integration), while advocates generally agree with the proposal, we are take issue with the assumption that a move to much greater consolidation among providers is both inevitable and should be facilitated, when such consolidation may in fact be harmful to the goals of improvin