CMS-10408.Public Comment 11_17_11

PUBLIC SUBMISSION

As of: November 17, 2011 Received: November 16, 2011 Status: Draft Category: Individual - I0001 Tracking No. 80f6e238 Comments Due: November 16, 2011 Submission Type: Web

Docket: CMS-2011-0171
Early Retiree Reinsurance Program Survey of Plan Sponsors (CMS-10408)

Comment On: CMS-2011-0171-0001
Early Retiree Reinsurance Program Survey of Plan Sponsors (CMS-10408)

Document: CMS-2011-0171-DRAFT-0001
NY

Submitter Information

Name: Martin Hill
Address:

New York,  NY,  10017

Organization: PwC

General Comment

Regarding question #17, employers will have a very difficult time in estimating the cost savings. In most all cases, the actual cost savings amount will be unknown or even unknowable as it pertains to what the costs would have been if the particular program or procedure were not in place. It's theoretical.
Cost savings programs such as disease management and others have long been criticized by employers and others for not having a tangible or measurable "return on investment", yet that's essentially what CMS is asking employers to estimate on this question.
Utilmately, employers will look to either consultants or providers of those programs for an estimate, and in many cases the estimate will be a "blind guess" at best.

Perhaps instead of quantifying the savings, CMS could ask employers to list the estimated number of participants who have the high-cost conditions?