Community Comments: Planned Parenthood

HCA recently released the draft Medicaid Transformation Project Toolkit for a public comment period. 

A number of our Leadership Council members have shared feedback on the projects called out in the Toolkit, which we would like to share with you. Here are comments sent from Planned Parenthood of Greater Washington and North Idaho: 

We are pleased to see that the current draft includes reproductive health under the optional section on Maternal and Child Health, but we urge that the name of the section on Maternal and Child Health be changed to “Reproductive Health.” Language throughout the section referring to women’s health only in relation to their potential future pregnancies should also be changed to simply refer to reproductive health or family planning. The language of the section as written indicates a value on women’s health only if they actively intend to become pregnant, and while the state has an interest in healthy pregnancies and births, the state also has an interest in healthy women who have the care, privacy, and respect to determine when and whether to become pregnant.

We also strongly suggest that the section on Maternal and Child Health / Reproductive Health be made a required project, not optional, due to the tremendous benefits to public health and health care spending that are achieved when women have access to reproductive health and family planning services. Furthermore, the target population should be enlarged to include all adult women of reproductive age, typically defined as 18-44 years of age

We are pleased that the Toolkit draft includes suggested performance measures on unintended pregnancies, chlamydia screening, access to long acting reversible contraceptives (LARC), HPV vaccines, and other family planning-related items. However, we strongly support additions and adjustments in order to more fully reflect a more robust set of measures relevant to reproductive health as well as maternal and infant outcomes:

  • Pre- and post-natal care quality measures, (which are captured in the Regional Health Needs Assessment), BMI screening, breast and cervical cancer screening, STI screenings, and tobacco use screening and cessation counseling.
  • Use a contraceptive care measure that covers a range of effective methods so that one method is not prioritized or incentivized over another. NQF#2903 and its companion NQF#2902 for post-partum care are generally more appropriate for measuring clinical quality of contraceptive care. They both measure provision of a most effective (i.e., sterilization, implants, intrauterine devices or systems (IUD/IUS)) or moderately effective (i.e., injectables, oral pills, patch, ring, or diaphragm) FDA-approved method.
  • Consider adding a measure related to contraceptive counseling, such as the 11-item Interpersonal Quality of Family Planning Care (IQFP) scale OPA is proposing to develop for endorsement.[1]

Additional suggestions for improvements to the Toolkit draft include:

  • Recognize the role of family planning and reproductive health providers explicitly as likely partners for projects throughout the Toolkit
  • Include ACH projects designed to improve quality and access for women of reproductive age. The goals of Transformation would be better served with more focus on serving the state’s women and youth. To this end, there is a need for specific Toolkit projects that address the needs of women of reproductive age and invest in the community providers that serve them with high-quality, culturally competent reproductive care and coordination.
  • Add a project to reduce unintended pregnancies statewide. This would be consistent with the state’s Common Measure Set, which includes unintended pregnancy as a key performance objective.

Sexual and reproductive health care providers serve a critical and unique role in supporting the goals of Transformation. We urge that the reproductive health projects and measures in the Toolkit be maintained and improved, and that the role of reproductive health be more explicitly stated throughout the toolkit as a key part of many of the projects included and a critical component of a sustainable transition to value-based payment and achievement of the triple aim of better care, lower costs, better health.