1400 Eye Street, NW
Suite 330
Washington DC 20005
phone 202.331.4601 fax
202.296.3526
Darnell Dent, Chairman
Margaret A. Murray, Executive Director
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January 22, 2002
CMS Office of Information Services Security and Standards Group Division of CMS Enterprise Standards Attention: Julie Brown CMS-R-305 Room N2-14-26 7500 Security Boulevard Baltimore, MD 21244-1850
To Whom It May Concern:
The Association for Health Center Affiliated Health Plans (AHCAHP) is pleased to comment on the proposed protocols governing external review organizations in Medicaid.
AHCAHP is made up of 17 member plans which serve primarily the Medicaid and SCHIP population. Our mission is to improve the health of medically underserved populations through the development, survival, promotion and growth of Community Health Center-affiliated health plans. The 17 member plans serve over one million beneficiaries in thirteen states.
Our main comment is that we do not believe there exists a necessity for an external review every year. If an organization has no “negative findings” in one year, we would suggest that the state not be required to conduct the same review the following year. Instead the reviews could be done every two years for areas with positive findings.
We found that the protocols were very clear as to what needs to be collected.
Sincerely,
Margaret A. Murray Executive Director
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