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Show regard, the voluntary cooperatives operating in the Utah market will be an important testing ground for determining the real gains associated with consolidating buying power. If the gains are real, and not simply redistribution across participants, then small employers should want to join together to obtain those gains and a voluntary mechanism may be sufficient to avoid the more heavy-handed mandatory arrangement currently under consideration. If the gains are not real, then the experience gained under this voluntary system may allow policy makers to prevent the upheaval of forcing every small employer and individual into an unsuccessful purchasing cooperative. In addition to these initial efforts at expanding access is a series of changes designed to increase information in the reform process and the health care marketplace. At the center of this information process is the creation of the Utah Health Policy Commission, charged with the task of analyzing potential health reforms and making recommendations to the Legislature. Evaluation can only improve Utah's efforts to design a workable reform within such a complex industry. However, the analytic approach designed in this legislation is not without potential pitfalls. The governor has argued for an open, flexible process that only moves forward after evidence and research have confirmed the validity of the proposed reform. Given this structure, it is important that we clearly define the criteria by which the Commission will implement the governor's plan and the conditions under which the Commission might reject the proposed plans. Establishing the criteria by which proposed reforms will be accepted or rejected is also essential to the legitimacy of the evaluative process and reform in general. Legislators and citizens can only be confident of the results of the planned analysis if they have early access to the Commission's assumptions, data sources, and criteria used to reach those conclusions. Additionally, the time frame the governor has outlined makes evaluation problematic. Often the plan calls for evaluation of one reform in the first year of its implementation to be used as justification for further actions. It is unlikely, however, that the impacts of many of these reforms will be evident so soon. Effects measured during implementation can be very different from the effects even one year later. Yet the governor's plan depends on these short evaluation time frames for moving forward with additional plan components. For example, when the federal government designed the Medicare system, analysis of financing changed dramatically over a single year of experience (Tanner, 1993). Measurements taken at a single point can tell a very different story from the culmination of measurements taken over a longer period of time. While good analysis is not impossible under such conditions, those involved should use caution in drawing conclusions based on short term evaluations. A further consideration in the analysis or evaluation process involves what is comparable in terms of data drawn from policy changes in other states. It is important that we draw on analysis of experiments elsewhere, but it is also critical for the analyst to be sensitive to the special circumstances and features of Utah's health care market. Utah has a healthier population, lower overall per capita health care costs, and greater concentration in the health care delivery and financing systems than most other states. These differences make interstate comparisons difficult. Analysis should draw on Utah's actuarial data to determine to what extent changes observed elsewhere might be replicated in the Utah market. In addition to the information gains associated with the Commission structure, several features of the legislation are designed to increase information for consumers, employers, and providers faced with health care decisions. If consumers and sophisticated purchasers are to make efficient decisions affecting cost and quality, expanded sources of information will be essential. In the governor's plan, the expansion of existing data systems, the creation of benchmark benefit plans, and increased quality control information are all important steps in this direction. Similarly, if we expect individuals to use vehicles like Medicine accounts (tax-deferred savings accounts intended for out-of-pocket medical expenses responsibly), they must have price and quality information publicly available. Rather than simply covering those practitioners involved in a particular health plan, every provider must make this information available. Only the state has the capability to enforce these reporting requirements. This effort should begin immediately, so that accurate analysis of the effects of these changes can be made in a timely fashion. The technical considerations of what data are relevant and how these should be reported will not be easy as policy makers strain between privacy considerations and the public's right to know. SB 158 started to wrestle with these issues, but several questions remain unsettled. For example, when the legislation calls for quality complaints to be reported, are they referring to complaints made to the health plan, complaints made to the insurance commissioner, or complaints made in Court? Obviously, many issues will require clarification before implementation. The usefulness of the information from insurers and providers required by Utah's Health: An Annual Review 1994 117 |