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Quality Reporting Requirements

Smart first steps


The Issue

Group health plans, except grandfathered health plans, will be required to satisfy new quality reporting requirements pursuant to standards to be issued by the Secretary of Health and Human Services (HHS). The reporting requirement will entail information about whether and how the plan’s benefits (and provider reimbursement structures) –

  • Improve outcomes through quality reporting, effective case management, care coordination, chronic disease management, and medication and care compliance initiatives;
  • Prevent hospital readmissions through a comprehensive hospital discharge program, including patient-centered education and counseling, comprehensive discharge planning, and post discharge reinforcement by an appropriate health care professional;
  • Improve patient safety and reduce medical errors through best clinical practices, evidence based medicine, and health information technology; and
  • Implement wellness and health promotion activities.

Plans will have to submit this report to HHS annually and make it available to enrollees during each open enrollment period. HHS will make the reports publicly available through the Internet.

Effective date: HHS is required to issue specific quality reporting standards by March 23, 2012. Group health plans are not required to begin complying with the related reporting requirements until after those standards are issued.

The quality reporting requirements do not apply to grandfathered health plans.

Key implication: Administration

Preparing the initial report may be a significant administrative burden for some plans. However, preparing updates for subsequent reports should be less burdensome.

Key implication: Plan design

The fact a group health plan’s report will be made available to enrollees, and published on the Internet along with reports by other group health plans, may result in pressure on the plan sponsor to bring its plan in line with the relevant coverage offered by other group health plans.

Smart first steps for employers to consider

Even before the HHS issues quality reporting standards, group health plan sponsors may want to begin assembling the relevant information about their plans. This will give employers a head start on preparing the initial report and assessing how well their plans meet these objectives. That, in turn, may give employers an opportunity to address any perceived shortcomings in their current plan designs before the information has to be reported to HHS and made publicly available.

As used in this document, “Deloitte” means Deloitte Consulting LLP, a subsidiary of Deloitte LLP. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries.

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