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Jan 16 -- The Centers for Medicare & Medicaid Services, Health and Human Services (HHS), invites comments to OMB by April 24, 2024 regarding the Quality Improvement Strategy Implementation Plan and Progress Report (CMS-10540). [Comments due 30 days after submission to OMB on March 25.]

Section 1311(c)(1)(E) of the Affordable Care Act requires qualified health plans (QHPs) offered through an Exchange must implement a quality improvement strategy (QIS) as described in section 1311(g)(1). Section 1311(g)(3) of the Affordable Care Act specifies the guidelines under Section 1311(g)(2) shall require the periodic reporting to the applicable Exchange the activities that a qualified health plan has conducted to implement a strategy as described in section 1311(g)(1). CMS intends to have QHP issuers complete the appropriate QIS forms annually for implementation and progress reporting of their quality improvement strategies. The QIS forms will include topics to assess an issuer's compliance in creating a payment structure that provides increased reimbursement or other incentives to improve the health outcomes of plan enrollees, prevent hospital readmissions, improve patient safety and reduce medical errors, promote wellness and health, and reduce health and health care disparities, as described in Section 1311(g)(1) of the Affordable Care Act.

The QIS forms will allow: (1) the Department of Health & Human Services (HHS) to evaluate the compliance and adequacy of QHP issuers' quality improvement efforts, as required by Section 1311(c) of the Affordable Care Act, and (2) HHS will use the issuers' validated information to evaluate the issuers' quality improvement strategies for compliance with the requirements of Section 1311(g) of the Affordable Care Act.

A Qualified Health Plan (QHP) issuer participating in an Exchange for two or more consecutive years must implement and report on a quality improvement strategy (QIS) or strategies, in accordance with section 1311(g) of the Patient Protection and Affordable Care Act (PPACA), to cover all its QHPs. The QIS requirements apply to all issuers offering QHPs through the individual marketplace or through the Small Business Health Options Program (SHOP). All QHP issuers must comply with the following requirements:

-- Implement a quality improvement strategy, defined as a payment structure that provides increased reimbursement or other incentives.
-- Implement at least one of the following:
   o Activities for improving health outcomes,
   o Activities to prevent hospital readmissions,
   o Activities to improve patient safety and reduce medical errors, and/or
   o Wellness and health promotion activities.
-- Implement at least one QIS that includes activities to reduce health and health care disparities.
-- Comply with guidelines established by the Secretary of Health and Human Services (HHS) in consultation with experts in health care quality and stakeholders.
-- Report strategy progress to the applicable Exchanges on a periodic basis.

All Exchanges are required to evaluate quality improvement strategies for issuer applicants. State-based Exchanges (SBEs) will evaluate the strategies of the issuers applying to offer QHPs in their respective Exchanges. The Centers for Medicare & Medicaid Services (CMS) will evaluate the strategies of issuers applying to offer QHPs in most Federally facilitated Exchanges (FFEs). In FFEs where States perform plan management, issuers applying to offer QHPs will undergo a joint review of their quality improvement strategies by the State and the FFE. CMS requests approval from the Office of Management and Budget (OMB) for the renewal of the information collection associated with the QIS requirements.

CMS Quality Improvement: https://www.qhpcertification.cms.gov/s/Quality%20Improvement
CMS submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202403-0938-011 Click IC List for information collection instrument, View Supporting Statement for technical documentation. Submit comments through this webpage.
FRN: https://www.federalregister.gov/d/2024-00657 #3

For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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