ITUP Comments on Exchange Stakeholder Questions

April 3, 2012

The Exchange recently sought stakeholder comments on qualified health plans (QHP), benefit design and delivery system reform to foster better value and enhanced quality in California through a series of extensive questions.  The following is ITUP’s comments; the full document is available for download.


Dear Peter,

Thank you for the opportunity to comment on the proposed criteria for qualified health plans contracting with the Exchange. Insure the Uninsured Project’s top priorities are price, quality, simplicity to the consumer, innovative approaches to reducing health costs and improving health outcomes, long-term price stability and timely access to the essential health benefits. We will try to answer as many of your thoughtful and detailed questions as we think we have helpful input.

We think all participating plans should meet Knox-Keene licensure requirements as they provide the strongest consumer protections under California law and offer greater value due to their better controls on price, quality and utilization.

  1. We think the Exchange should review plans’ history of consumer complaints and regulatory enforcement actions (if any) at DMHC, CDI, DHCS, MRMIB and Office of the Patient Advocate to determine whether potential contractors provide excellent service and access to care for
  2. We think that the Knox-Keene standards under DMHC are stronger than the CDI standards and would urge you to use DMHC standards for all QHP’s.
  3. Knox-Keene, Medi-Cal and Healthy Families all have quality, access and consumer protection standards. In the interests of expediting and simplifying contracting, we would urge you to use the Knox-Keene standards.
  4. We think all eight are vital priorities. Our top three are 5(c), (affordability, price and value), 5(e) (promoting healthy lifestyles and use of prevention), 5(d) (a carrier’s track record) and 5(b) (culturally and linguistically appropriate services and providers).


The rest of the comments are continued in the document below:
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