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ADMINISTRATIVE
CONFIDENTIAL Adv Com Reg Reform Pre-decisional Working Document -- DO
NOT RELEASE
1-17-02
DRAFT
FOR COMMITTEE DISCUSSION ONLY--
SECRETARYS
ADVISORY COMMITTEE ON REGULATORY REFORM
PROPOSED
ISSUE SELECTION AND PRIORITIZATION CRITERIA
The
Advisory Committee is charged with addressing a broad range of regulatory
issues (i.e., health delivery systems, research, operations,
pharmaceutical/biologic/device development) that apply to a wide variety
of stakeholders (e.g., providers, consumers, insurers, manufacturers). The
Advisory Committees ultimate goal will be to identify and prioritize
the barriers that get in the way of "doing the job" and
delivering high quality and safe care, services, and products to patients
and consumers. To ensure that high priority objectives are accomplished,
the Advisory Committee will adhere to a set of rules for deciding which
specific problems it can tackle and what kinds of solutions it can offer.
Following is a proposed set of principles that will help the Advisory
Committee focus its efforts.
The
Advisory Committee will...
- Make
every effort to develop recommendations about issues or problems
that have the most significant and most direct effect on
improving care and services to patients and consumers.
- Concentrate
efforts on existing programs or policies and focus on solutions
for reducing impediments to realizing current goals.
- Select
issues for deliberation on which meaningful progress can be made
during the year, but that may not be entirely resolved, in
addition to identifying and "fixing" several concrete
problems. The Committee will identify a mix of immediate fixes
(what can be done now), short-term fixes (what can be done in 6
to 12 months), and long-term fixes (beyond one year). Staff will
provide assistance to members regarding what can be done by
Executive Order, regulatory modification, or legislative change.
The Committee will consider recommendations from the legislative,
and executive branches of government as well as other sources
(e.g., recommendations from physicians, health plans and
providers, beneficiary advocates and beneficiaries, academic
experts and the public).
- Consistent
with the Committees mission, concentrate on and prioritize
operational issues or problems that will have the greatest impact
for the greatest number of stakeholders and program dollars, to
the best of our ability. For example, the Secretary recently
cited the Medicare Secondary Payer form as a source of burden for
both beneficiaries and providers because of the frequency with
which it is required to be completed. Recent steps to reduce this
frequency will have an impact on many stakeholders.
- Attempt
to identify the intent of the law and develop recommendations
that will maintain or improve on the way in which that intent is
accomplished. Focusing on the intent of the law will help the
Committee to recognize competing objectives and interests in the
regulatory scheme and will help determine how those interests can
be balanced. If the Committee believes that it cannot achieve an
objective by modifying the regulatory process or the regulation
itself, then statutory changes consistent with this objective may
be recommended.
- The
Advisory Committee will focus on how policies are
implemented and not on the underlying statutory policy that
may be necessary.
- The
Advisory Committee will consider new ways of achieving a
given policy goal, and not confine itself to tinkering
around the edges of existing structures and processes.
6.
Attempt to identify problems that are likely to occur on an
ongoing basis. While the Advisory Committee will likely hear
testimony on past transitional problems, it should focus on
persistent problems.
7.
Consider the budget implications to the program trust fund and/or
to the discretionary funding necessary to operate the program, as
part of any recommendation made.
The
Advisory Committee will not
- Assess
the adequacy of payment levels or the fairness and accuracy of
payment methodologies. Providers sense of burden may be
closely related to their sense of being underpaid. However, this
issue is beyond the Committees charge.
- Engage
in "what if" scenarios about program statistics (e.g.,
changes in Medicare fee-for-service, managed care enrollment, and
provider participation rates).
- Pursue
new policy goals.
- Prioritize
or make recommendations on issues that are anecdotal or relevant
only to specific special interests.
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