| Proposed
Changes to Hospital Outpatient Payment System and 2002 Payment Rates for
Medicare - October 3, 2001
AHQA
Comments: AHQA is concerned that the proposed rule will interfere
with an existing multiyear initiative at the Centers for Medicare and
Medicaid Services (CMS) designed to improve the quality of care provided
to Medicare beneficiaries. CMS has already invested significant resources
to increase the frequency with which mammography services are utilized
by Medicare beneficiaries. AHQA is opposed to any rule that reduces
ready access to these vital and demonstrably underutilized mammography
services. More…
Comments
to Inform the HHS Initiative on Rural Communities -
September 27, 2001
AHQA
Comments: Two well-respected federal organizations recently recognized
that the quality of care in rural areas could be improved, just as it
can in urban areas, but that appropriate resources and tools are necessary.
They both recommend utilizing the QIOs to provide the necessary technical
assistance and expertise to improve care in rural facilities. More…
AHQA
Letter to CMS Regarding the Designation of PRO-Like Entities,
September 13, 2001
Letter of September 13, 2001
Statement
to CMS on Use of Physician Query Forms — July 27, 2001
AHQA
Comments: AHQA has serious reservations about any guidance that
would limit the use of properly designed query forms or their acceptance
as a component of the medical record. The query form has long been considered
a useful communication tool, but not a substitute for clear and accurate
documentation. More…
AHQA
Comments to CMS on Evaluation Criteria and Standards for PRO 6th Round
Contract (June 25, 2001)
AHQA
Letter to CMS on Uses of MPSMS Data (May 10, 2001)
AHQA
Response to the Strategic Framework Board of the National Quality Forum
May 2001
Comments
on Federal Patient Data Privacy Rules - March 2001
AHQA
Comments: In this regulation, the primary question for external
organizations like QIOs that rely on provider data for data analysis
is: under what circumstances are covered entities allowed to give QIOs
protected information without individual authorizations? This letter
includes recommendations that would clarify the circumstances under
which QIO work with government agencies should be considered oversight,
and the appropriate parameters for QIOs when considered business associates
with covered entities. More…
Comments
on Proposed Improvements to the Medicare+Choice Appeals and Grievance
Procedures - March 2001
AHQA
Comments: Instead of designating that QIOs should extend their work
in hospitals to other settings, the regulation is silent on what type
of entity should be qualified to become an Independent Review Entity
(IRE). QIOs already interact on a daily basis with families that question
whether the timing of a provider discharge affecting a loved one is
appropriate. Relying on entities other than QIOs will be confusing to
beneficiaries and providers…and deprives beneficiaries of protections
established in the carefully crafted federal QIO statute. More…
Comments
on the Medicare Beneficiary Complaint Process - March 2001
AHQA
Comments: AHQA recommends a thorough restructuring of the complaint
program. We have concluded that CMS and its QIO contractors can and
should do more to make the beneficiary complaint program better known,
as well as more responsive to the consumer. While some deficiencies
in the current program can be addressed directly by QIOs, the resources
currently invested in this program by the federal government are insufficient
to respond to many challenges. More…
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