Appendix F2 – Public Comments AHRQ Response

September 29, 2014
VIA ELECTRONIC TRANSMISSION
Ms. Doris Lefkowitz
Report Clearance Officer
Agency for Healthcare Research and Quality
Department of Health and Human Services
540 Gaither Road
Rockville, MD 20850

Re:

Agency Information Collection Activities: Proposed Collection; Comment Request: Care
Coordination Quality Measure for Patients in the Primary Care Setting

Dear Ms. Lefkowitz:
Planned Parenthood Federation of America (“Planned Parenthood”) and Planned Parenthood Action
Fund (“the Action Fund”) are pleased to submit these comments on the proposed Care Coordination
Quality Measure for Patients in the Primary Care Setting project. As a trusted women’s health care
provider and advocate, Planned Parenthood supports the Agency for Healthcare Research and Quality’s
(AHRQ’s) work to facilitate better care coordination as a part of improving health outcomes. At the
same time, it is essential that the unique health care needs of women are integrated into this effort.
Indeed, doing so would align with the U.S. Department of Health and Human Services’ (HHS’s) efforts to
ensure the delivery of high quality family planning services, in line with the recent release of the Quality
Family Planning Services Guidelines.
Conversations about primary care too often ignore the reality that the main health care services many
women, and especially younger women, are seeking are reproductive health services. Recent research
underscores the fact that the majority of health care services women access are women’s health
services. This research found that the top services women said they needed in the last two years were
annual exams (56 percent), a Pap test (49 percent), and birth control (34 percent).1 This research
reinforces that discussions about primary care and how to measure quality of care must include an
emphasis on women’s health care.
As the AHRQ is seeking to develop quality measures that accurately quantify the quality of care patients
are receiving in a primary care setting, we recommend that measures be included that reflect the care
women need. For women, one of the most important components of their care centers on reproductive
health care and family planning. We recommend including the following questions to ensure primary
1

PerryUndem Research & Communication. “Women & OB/GYN providers”. Research conducted for Planned
Parenthood Federation of America, November 2013.

care providers are having conversations with women about family planning and are ensuring women are
using contraceptive methods that meet their needs.
1. Did your health care provider ask if you would like to become pregnant in the next year?
2. If you have been prescribed any birth control method, have you continued to use the method
you were prescribed?
3. If you are using a birth control method, were you asked whether you are satisfied with your
method of birth control?
These questions are important for ensuring women are receiving high quality family planning care. In
fact, some states are beginning to incorporate them into quality initiatives. For example, the state of
Oregon has an initiative encouraging primary care providers to ask female patients if they want to
become pregnant in the next year as a way of beginning a conversation about family planning if
appropriate. Researchers estimate that by asking this question in Oregon—a state with a nearly 50
percent unintended pregnancy rate—it could prevent 90% of unintended pregnancies and save $75.5
million per year.2 This estimate is consistent with longstanding research demonstrating that family
planning improves infant and maternal health outcomes and saves millions of dollars.3
Planned Parenthood looks forward to continuing to work with HHS to ensure a high quality of care
coordination is provided to women in a primary care setting. Thank you for the opportunity to
comment on Care Coordination Quality Measure for Patients in the Primary Care Setting. If you have
any questions, please do not hesitate to contact me at 202-973-4800.

Respectfully submitted,

Dana Singiser
Vice President of Public Policy and Government Relations
Planned Parenthood Action Fund
Planned Parenthood Federation of America
1110 Vermont Avenue NW, Suite 300
Washington, DC 20005

2

The One Key Question. http://www.onekeyquestion.org/ (accessed September 23, 2014)
Frost, Jennifer, et al. “Contraceptive Needs and Services, 2010.” Guttmacher Institute. July 2013.
http://www.guttmacher.org/media/nr/2013/07/30/ (accessed September 23, 2014)
3