Comment on FR Doc # 2011-02254

File Code OCIIO-9983-NC To: Secretary of Health and Human Services Re: Comments regarding the Consumer Oriented and Operated Plan Program The CO-OP plan program has the potential to be a driver of significant reform in the delivery and financing of health care. Has the possibility of health care “niche or segment” non-profit insurance plans been considered? One possibility would be the large niche of pregnancy care. The current US pregnancy care system provides care to 4 million mother/baby pairs at a cost of more than $38 billion dollars. This system is poorly coordinated and provides less than optimal care at a high price – especially to the 40% of mothers who receive care within publicly sponsored programs. Many parts of the Affordable Care Act encourage needed pregnancy care reforms (enhancing the role of midwives and birth centers as one example). The CO-OP plan program could have a very positive impact if it encouraged the formation of pregnancy care plans that provide comprehensive care for a single bundled price. The change in the payment model from a fee for service system to bundled payments for pregnancy care will stimulate innovation and will restrain costs. Encouraging non-profit pregnancy care plans in the CO-OP plan program would be very beneficial. Health care reform should start where we all did - with pregnancy and birth. Steve Calvin MD Specialist in Maternal-Fetal Medicine Minneapolis, MN Calvi002@mac.com 612-868-9199