The AAMC March 25 submitted comments to the Department of Veterans Affairs (VA) on access standards and eligibility requirements in the community care program proposed rule, released Feb. 22. The proposed rule, one step in the implementation of the VA MISSION Act passed in June 2018, outlines six eligibility requirements, including access standards, that a veteran would need to meet in order to seek care outside of the VA system [see Washington Highlights, March 1].
The AAMC’s comments focused on reaffirming the relationship between the VA and academic medical centers (AMCs), and the important joint missions of clinical care, research, and education. The AAMC noted language in the proposed rule that could prohibit a provider from being an eligible provider in the new community care program despite being part of the VA or employed by the VA. Because AMCs have providers that may be dually employed by the VA and the AMC, the AAMC urged the VA to ensure that these providers would maintain their ability to provide care in the VA and in their AMC, potentially under a community care contract.
The AAMC encouraged the VA to continue evaluating their proposed eligibility criteria as the program develops and ensure that access standards provide an exceptions process for the largely arbitrary standards in the event of an urgent or time-sensitive clinical situation. Additionally, the AAMC encouraged the VA to review a variety of methods to evaluate and establish network adequacy. The AAMC also encouraged the VA to continue expanding telehealth options, while maintaining veteran choice if the veteran preferred an in-person visit, and to consider implementing interprofessional internet consultations to enhance access.
The AAMC urged the VA to release their report on quality standards and metrics and make it available for public review and comment. The AAMC also encouraged the VA to use quality measures in the community care program that are meaningful to the unique population that the VA serves, and stated that these measures should be risk-adjusted and thoroughly vetted through a consensus-based entity that includes multiple stakeholders. These measures should be aligned with measures used by other payers to the extent possible.
The AAMC was pleased to see the proposed rule affirmed maintaining the option for veterans to continue to seek care through the traditional VA system, even if one or more of the eligibility criteria for non-VA care was met, provided that this choice would not have a negative impact on their care.
The AAMC also provided comment on proposals related to emergency care, prescription drugs, and interoperability of EHRs and portals.