First Focus on Children submitted the following comment to Secretary of Health and Human Services, Xavier Becerra and the Administrator of the Centers for Medicare and Medicaid Services (CMS) at the U.S. Department of Health and Human Services, Chiquita Brooks-LaSure focused on the Child Core Set and the behavioral health measures on the Core Set of Adult Health Care Quality Measures.
Excerpt from the Comment:
The COVID-19 pandemic has further illuminated the health disparities that exist for children of color, who are enrolled disproportionately in Medicaid and CHIP. Stratifying quality measures, particularly by race and ethnicity, is essential to improving child, maternal, and behavioral health and addressing health disparities that exist people of color. However, we recognize that states face challenges in stratifying measures, particularly as it relates to race and ethnicity, and generally support the proposed rule’s phased-in approach to stratification. We also agree with the proposed rule at §437.10(d) that the Secretary should specify which measures must be stratified in order to promote consistency and comparability across states rather than allowing states to choose. We urge the Secretary to prioritize how stratification is phased in based on the areas of most urgent need, including maternal and behavioral health. We also recommend that stratification by health plan, as required in the statute at §1139A(b)(2)(C), be specified in the regulation. A majority of Medicaid beneficiaries are enrolled in managed care plans but there is limited public data assessing access and the quality of care, which varies widely across different states and health plans. We believe it’s important to specify stratification by health plan in the regulation.