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CHA submitted the attached comment letter to the Centers for Medicare & Medicaid Services (CMS) today in response to CMS’ request for information on core access to care measures and metrics that could be used to assess access in the Medicaid program. CHA encourages CMS to take a thoughtful approach and develop an action plan that would ensure successful implementation of CMS’ goals for the program.
More specifically, CHA recommends that CMS develop and implement a National Access Strategy, similar to its approach when developing the National Quality Strategy, and allow multi-stakeholder and multi-agency participation in the process. CHA also urges CMS to look beyond traditional metrics to identify new evidence-based areas for measure development and to identify measurement gaps. CHA recommends that CMS consider environmental factors such as poverty, access to transportation and affordable housing when evaluating a beneficiary’s access to care. These factors can have significant impacts on patient health and health care delivery and should receive consideration. While CHA appreciates CMS’ efforts to create an equitable health care system, CHA requests that CMS recognize the costs of providing health care when it determines whether rates are adequate to ensure access. CMS must ensure that payment rates remain adequate for hospitals that are asked to do more with less.
