Comment on FR Doc # 2011-02254

Please see uploaded document for full comments from CareOregon “Regarding Provisions of Consumer Operated and Oriented Plan Programs.” We make four basic points: 1. The serious problems of health care cost and quality in the United States can only be addressed with fundamental and transformational changes in the way health care is organized and delivered. The goal is the Triple Aim; a concept now common in agency conversation, meaning improved individual experience, world class population health, at lower per capita costs. 2. Health care is more than medical care. To achieve the Triple Aim, we must rethink health care as a mix of population-based community and social services, with timely and necessary access to medical, dental, behavioral, and long-term care. 3. Consumer directed health care is an important public policy and should be part of every health care system in the United States. Consumers must have a role not only in health care finance, but also in health care organization and delivery. CareOregon has adopted member-centricity as one of our core values, with responsibility for this part of our mission assigned to a board level committee made up of corporate directors, member-customers, and senior management. 4. Organizing a new co-operative insurance company or health plan is serious business. It will take substantial financial and human capital. The only way that a newly-formed cooperative under the Affordable Care Act can be successful is if the regulations allow such an entity to be sponsored and supported by an existing enterprise with sufficient experience and resources. Testimony before the Advisory Committee, and the comments of the committee members themselves, are consistent with this observation. We urge the Advisory Committee to advance recommendations which will allow newly formed consumer organizations to form open and transparent business arrangements with existing non-profit community enterprises, such as CareOregon.