NHeLP Comments to Agency for Healthcare Research and Quality Regarding Priority

Agency for Healthcare Research and Quality
Attention: Office of Extramural Research, Education & Priority
Populations-Public Comment CHIPRA PQMP Priorities
540 Gaither Rd. 
Rockville, MD 20850
Re: Priority Setting for CHIPRA Pediatric Quality Measures Program
Dear AHRQ:
The National Health Law Program (NHeLP) is a public interest law firm working to improve and protect the legal rights of vulnerable people to quality health care. Over its 40-year history, NHeLP has worked extensively with children, parents, and other child health advocates on children?s health issues. We appreciate the opportunity to comment on the AHRQ?s December 3, 2010 request for comments regarding Priority Setting for CHIPRA Pediatric Quality Measures Program. 75 Fed. Reg. 75469 (Dec. 3, 2010). We support 
this important process of developing a comprehensive set of quality measures for children and support the comprehensive approach you are taking. We endorse the comments submitted by the American Academy of Pediatrics and also urge you to consider the following additional issues: 
  1. Section 1 (Development or enhancement of methods) subsection a. discusses standardized measures. While we support a unified medical record, we caution that the information being collected needs to comply with and include the requirements Congress has set forth for reporting of Medicaid Early and Periodic Screening, Diagnostic and Treatment (EPSDT) services, as reflected by the CMS Form 416. The CMS Form 416 gathers information from each state about these legally mandated measures regarding the availability and use of preventive services by Medicaid-eligible children and youth, see 42 U.S.C. § 1396a(a)(43). While we appreciate the need for duration of enrollment calculations for many measures, we must point out that, to comply with Medicaid EPSDT reporting, the statutory requirement is to provide the information for all enrolled children and youth. It is children who are experiencing interruptions in enrollment who may be most likely to fall through the preventive care and treatment cracks. 
  2. Section 1 (Development or enhancement of methods) subsection b. lists benchmarks for assessing disparities in quality. We suggest that assessment by race include uniform collection of data of sub-groups of larger racial categories. We also suggest that you assess disparities by primary oral and written language used in the household and family status of the child (e.g. whether the child is in out of home placement).
  3. Section 2 (Specific care settings and conditions) subsection b. references availability of services. We ask that you to add ?access? to services. In some cases, even when services are available, barriers to access may prevent children from getting the services they need.
  4. Section 2 (Specific care settings and conditions), subsection e. lists focus areas. We urge you to include measures related to:
  • oral health care;
  • childhood obesity/body mass index;
  • vision and hearing assessments; 
  • mental/behavioral health and substance use services, particularly related to 
  • adolescents; 
  • evidence based, clinical approaches (e.g. ABA therapy);
  • hospital admission/re-admission for conditions that can/should be treated in the 
  • community (e.g. asthma);
  • children and youth with special health care needs who are experiencing transitions
  • to and from more restrictive institutional settings (including correctional settings) 
  • and home and community-based settings; and 
  • children and youth with special health care needs as they experience care 
  • transitions, including transitions to adult services. 
Thank you for considering these comments. If you have questions, please contact me at 
Jane Perkins
Legal Director

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