On November 1, 2022, letters (option 1; option 2) with 36 signatures were provided to the Oregon Health Evidence Review Commission (HERC) related to its proposed guide for use of quality-adjusted life years (QALYs) in HERC’s meeting materials, processes and decisions, particularly related to the prioritized list of services for coverage under Medicaid.
Patients and people with disabilities, as they commented in the past, stated the use of QALYs has no place in health care decisions due to their inherent discriminatory algorithms that drive health inequity. Advocates provided separate letters on Options 1 and 2 in order to meet the restrictive 1000 word limit on comments required by the HERC. Advocates clearly stated that the alternatives in front of the HERC do not sufficiently address the shortcomings of QALYs.
Additionally, other Oregon-based advocates provided separate letters to the HERC. Paul Terdal noted that the assertion in Option 1 that “QALYs will not inform scoring used to rank lines for the Prioritized List” won’t really be true in practice – if QALYs are used in any way to determine what services are included on a list, or guidance notes for how services on the list are to be covered, then any service that is not included (or excluded in part based on guidance notes) is automatically ranked “below the line” and is excluded from coverage. For Option 2, he noted that where QALYs aren’t discussed openly at Commission meetings, and references to QALYs are redacted – simply hides use of QALYs from public view if Commission reports are based on research findings derived from use of QALYs. Hiding this use of QALYs from public view by redacting them may also violate ORS 192.314, Right to inspect public records.
Lorren Sandt with Caring Ambassadors emphasized the need to table the decision until the HERC is able to convene a panel of experts to educate the HERC on the implications of Oregon’s continued use of QALYs.
Additionally, other Oregon-based advocates provided separate letters to the HERC. Paul Terdal noted that the assertion in Option 1 that “QALYs will not inform scoring used to rank lines for the Prioritized List” won’t really be true in practice – if QALYs are used in any way to determine what services are included on a list, or guidance notes for how services on the list are to be covered, then any service that is not included (or excluded in part based on guidance notes) is automatically ranked “below the line” and is excluded from coverage. For Option 2, he noted that where QALYs aren’t discussed openly at Commission meetings, and references to QALYs are redacted – simply hides use of QALYs from public view if Commission reports are based on research findings derived from use of QALYs. Hiding this use of QALYs from public view by redacting them may also violate ORS 192.314, Right to inspect public records.
Lorren Sandt with Caring Ambassadors emphasized the need to table the decision until the HERC is able to convene a panel of experts to educate the HERC on the implications of Oregon’s continued use of QALYs.
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| hhs_letter_to_oregon_1992.pdf |
