10-19-10
AOTA Comments on The National Health Care Quality Strategy and Plan
The Patient Protection and Affordable Care Act (ACA) includes an array of provisions designed to ensure health care coverage and quality. Specifically, Section 3011 of the ACA calls on the Department of Health and Human Services (HHS) to establish a National Health Care Quality Strategy and Plan and identify priorities to improve health care service delivery, patient outcomes, and population health. HHS solicited comments on the National Health Care Quality Strategy and Plan, and on October 25, 2010, AOTA submitted comments regarding the framework, structure, principles, and conceptualization of the Strategy and emphasizing the preventative and effective role of OT in coordinated quality care. Below are the 10 questions posed by HHS and answered in AOTA’s comments:
Question 1: Are the proposed Principles for the National Strategy appropriate? What is missing or how could the principles be better guides for the Framework, Priorities and Goals?
Question 2: Is the proposed Framework for the National Strategy sound and easily understood? Does the Framework set the right initial direction for the National Health Care Quality Strategy and Plan? How can it be improved?
Question 3: Using the legislative criteria for establishing national priorities, what national priorities do you think should be addressed in the initial National Health Care Quality Strategy and Plan in each of the following areas. Better Care: Person-centered care that works for patients and providers. Better care should expressly address the quality, safety, access, and reliability of how care is delivered and how patients rate their experience in receiving such care; Affordable Care: Care that reins in unsustainable costs for families, government, and the private sector to make it more affordable; and Healthy People/Healthy Communities: The promotion of health and wellness at all levels.
Question 4: What aspirational goals should be set for the next 5 years, and to what extent should achievable goals be identified for a shorter timeframe?
Question 5: Are there existing, well-established, and widely used measures that can be used or adapted to assess progress towards these goals? What measures would best guide public and private sector action, as well as support assessing the nation's progress to meeting the goals in the National Quality Strategy?
Question 6: The success of the National Health Care Quality Strategy and Plan is, in large part, dependent on the ability of diverse stakeholders across both the public and private sectors to work together. Do you have recommendations on how key entities, sectors, or stakeholders can best be engaged to drive progress based on the National Health Care Quality Strategy and Plan?
Question 7: Given the role that States can play in organizing health care delivery for vulnerable populations, do the Principles and Framework address the needs and issues of these populations?
Question 8: Are there priorities and goals that should be considered to specifically address State needs?
Question 9: What measures or measure sets should be considered to reflect States' activities, priorities, and concerns?
Question 10: What are some key recommendations on how to engage with States and ensure continued alignment with the National Quality Strategy?
HHS’s initial Strategy is due to Congress by January 1, 2011 and must include provisions for: (1) agency-specific plans and benchmarks; (2) coordination among agencies; (3) strategies to align public and private payers; and (4) alignment with meaningful use of health information technology (HIT).
The Strategy is intended to be a living and changing guide for the Federal government, as well as for States and the private sector. The hope is that the Strategy will be sustainable over time, and support priorities and associated goals that will be periodically updated and refined to accommodate emerging issues. Updates on progress towards meeting the goals and priorities will be reported annually to Congress and the public.
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For more information see: www.hhs.gov/news/reports/quality/nhcqsap.html#question7
