Public Comment

The Green Mountain Care Board encourages Vermonters to comment on health system reform.

 

Here's how to comment:

1. You can always comment by filling out our Comment Form.

2. Sometimes there is an official comment period on a specific topic which will be listed on this page under Special Public Comment Period.

3. If you're looking for a specific GMCB open docket for the insurance rate review process or comment, go to our Rate Review page.

4. If you're looking for a specific GMCB Certificate of Need document, to our Certificate of Need page.

All public comments received by the Green Mountain Care Board are “public records” under Vermont law.  Absent a specific exemption to the Vermont Access to Public Records Act, any member of the public may access public comments by contacting us at 1-802-828-2177.  The Board may post public comments on its website, but will not post comments it finds to be inappropriate or comments that contain confidential information.  The Board may, however, redact confidential information from public comments and post the redacted versions. 

Special Public Comment Period

  The Green Mountain Care Board is seeking public comment on the proposed moratorium on changes to the quality and performance measures for year 3 of Vermont’s ACO shared savings programs. The comment period runs from Thursday, October 23 through Monday, December 1 at 4:30pm.”

 

 GMCB Statement Regarding Year 3 ACO Commercial Shared Savings Quality and Performance Measures:

The Green Mountain Care Board is considering a hiatus on adding or promoting quality and performance measures for Year 3 (Calendar Year 2016) of the ACO Commercial Shared Savings Program.  The Board requests that the VHCIP Quality and Performance Measures Work Group, Steering Committee, and Core Team also consider this proposal, which is based on a desire to provide stability and predictability to the program.  It will also allow the GMCB a chance to review and evaluate year 1 and 2 results of the ACO Commercial Shared Savings Program.

Specifically, the Board proposes the following:

  1. To allow ACOs to focus on enhancing data collection capability and improving quality of care and health outcomes, there will be a hiatus on changes to the measure set for Year 3, unless there are changes in measure specifications or in the evidence that serves as the basis for a particular measure.
  2. If a measure specification changes, the change would be incorporated into the measure set specifications, in accordance with “Vermont Commercial ACO Pilot Compilation of Pilot Standards: Section X. Process for Review and Modification of Measures Used in the Commercial and Medicaid ACO Pilot Program.”
  3. If a measure is no longer supported by evidence, the measure should be considered for elimination. If a measure is eliminated, the VHCIP Quality and Performance Measures work group could recommend replacing it with a measure that is supported by evidence, in accordance with “Vermont Commercial ACO Pilot Compilation of Pilot Standards: Section X. Process for Review and Modification of Measures Used in the Commercial and Medicaid ACO Pilot Program.”

 

There are two underlying reasons for the Board’s proposal.  The first is that significant time, energy and resources have been devoted to developing the Year 1 and Year 2 measure sets, without attaining consensus.  Understandably, participants in the measure development process bring a variety of valid perspectives to this work.  In general, providers are concerned that adding measures would increase administrative burden, dilute quality improvement efforts, and detract from patient care.  Advocates for additional measures want to ensure that the measure set is representative of various domains and populations, and that quality is monitored as cost-saving efforts are implemented.  Despite participants’ best efforts, consensus was not achieved for the Year 1 and Year 2 measure sets.  While the process was respectful, it was also divisive, time-consuming, and resource-intensive. 

Second, there is a lag in obtaining ACO performance measure results, and the Board would like to consider Year 1 and 2 results before making further changes to the measure set.  Results will not be available until the third quarter of 2015 for Year 1 of the program (2014), the third quarter of 2016 for Year 2 (2015), and the third quarter of 2017 for Year 3 (2016).  In fact, Year 1 and Year 2 results may not be available during the Year 3 measurement review process, and the ACO Commercial Shared Savings pilot will end before Year 3 results are available. 

The Board believes that it is not a good investment of time and resources to consider measure additions and/or promotions for Year 3 of the ACO Shared Savings Program, especially given Vermont’s dynamic health care reform landscape.  Therefore, we hope that everyone involved will see the value of the measures we have in place as well as the value of allowing some time to assess their impact.

 

Questions?  Call 802.828-2177 or e-mail GMCB.Board@state.vt.us