FW: CCO Proposed Administrative Rules - Public Comment

[Guest guest]

Ok, dear colleagues below is my personal “public comment” to the Oregon Health Authority’s Admin Rules coordinator Cheryl s which is where your comments should go. Please do me a favor and CC me your comments.

Lastly your comments can be short and sweet they do not have to be lengthy like the one below….Vern Saboe

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Vern Saboe, Jr, DC., DACAN., FICC., DABFP., FACO.

915 19th Ave SE

Albany, OR 97322

phone:

e-mail: vern@...

website: www.drvernsaboe.com

From: Dr. Vern Saboe

Sent: Friday, July 06, 2012 10:38 AM

To: 'PETERS Cheryl'

Subject: " CCO Proposed Administrative Rules - Public Comment "

Dear Ms. s there are three issues I wish to address within these proposed rules they are as follows.

1.

CCO member-patients must be allowed to select a chiropractic physician, naturopathic physician or nurse practitioner as their

“Primary Care Provider.” This fits with the philosophy of Governor Kitzhaber who has stated repeatedly that these provider types will be very instrumental in helping to fill the primary care provider shortage which is only going to worsen

when Oregon’s universal health care system comes fully on-line. Additionally, it has been estimated that roughly 78 million more Americans became Medicare eligible in January of this year. To that end clarification is needed in the current proposed language

found in; “ Integration and Care Coordination, (2)(a)” as it is unclear to the reader what constitutes an, “…eligible CCO participating provider type?” I would recommend the following additions to subsection “(a),”

(additional language is in red for clarification);

“(a) Demonstrate that each member has a primary care provider or primary care team that is

Responsible for coordination of care and transitions and that each member has the option to choose a

primary care provider of any eligible CCO participating provider type.

An eligible CCO provider type

would include any health care provider who can provide primary care services including chiropractic,

naturopathic, osteopathic, and medical physicians or a nurse practitioner.”

CCOs which attempt to prevent certain qualified provider types from providing primary care services would violate ORS Chapter 414 SECTION 4. (1) and as such clarification in the proposed administrative rules would be instructive.

2.

“Network adequacy;” as found in ORS Chapter 414 SECTION 4. (3) (a) must be defined within these proposed rules as it is

not defined in statute. “Network adequacy” is found in the proposed rules at; “ Operations and Provision of Health Services (6)(a)” I recommend the following definition;

“Network adequacy means a sufficient number of health care providers from each licensed health care

Profession such that all patient-members within the CCO can obtain care from the provider-type of

Their choice without unnecessary waiting periods or other restrictions?”

3.

“Varying reimbursement rates;” the new statute in ORS Chapter 414 SECTION 4. (1) allows for “…varying reimbursement rates based on

quality or performance measures.” We believe that administrative rule should clearly state “varying reimbursement rates” cannot be based solely on the provider’s area of practice or discipline which would violate the non-discrimination provision in

ORS Chapter 414 SECTION 4. (1). We would suggest the following additional language (in red) in the proposed rules under “OAR Operations and Provision of Health Services (4)(;

“Preclude the CCO from establishing varying reimbursement rates based on quality or performance measures. For purposes of this section, quality and performance measures include all factors that advance the goals of health system transformation, including

price. A CCO may not pay a different rate of reimbursement to a provider based solely on the provider’s area of practice or discipline.”

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Vern Saboe, Jr, DC., DACAN., FICC., DABFP., FACO.

915 19th Ave SE

Albany, OR 97322

phone:

e-mail: vern@...

website: www.drvernsaboe.com