The Massachusetts Medical
Society appreciates the opportunity to provide comment on a selection of bills
aimed at amending the authorities and processes of the Health Policy
Commission. The Medical Strongly supports and appreciates the role of the HPC
in promoting policies that to contribute to reductions in health care cost
growth and improvements to the quality of patient care.
As the Medical Society
acknowledges the unsustainable escalation of health care costs, we believe that
the authorities granted to the Health Policy Commission in Chapter 224 of the
Acts of 2012 are sufficient to thoughtfully promote cost containment in
Massachusetts. While health care costs continue to provide challenges
throughout the state, there are also many very positive signs in Massachusetts,
including annual growth in commercial health insurance premium spending per
enrollee in Massachusetts which has been roughly 2 percent per year since 2012,
significantly below national trend through 2015.
The Medical Society believes
that the authorities provided to the Health Policy Commission under Chapter 224
are appropriate, effective, and should not be altered at present. The cost
benchmark, the Cost Trends Hearings, and other associated authorities of the
HPC have driven discussion and increased transparency and accountability. Cost
and Market Impact Reviews and Performance Improvement Plans also provide
authority to the Commission to drive accountability and to promote cost
containment for specific proposed transactions and for individual physician
organizations, hospitals, and payers.
For these reasons, the Medical Society urges
opposition to the H. 591, An Act to strengthen the PIP process; H. 617, An Act
to prohibit material changes for above benchmark providers; H. 618, An Act
strengthening market impact review; H. 619, An Act enhancing the market review
process; and H. 2218, An Act relative to protecting health care consumer. The Medical Society does not believe that the
authorities of the HPC should be expanded, and opposes a prohibition of
material changes for organizations that exceed the benchmark. The current
formula of the benchmark means that certain factors such as changes in patient
population, increases in volume of patients, and changes in service line could
all lead to increases in THCE, but may not be reflective of low value, costly
care. Material changes should thus not be prohibited for organizations
exceeding the benchmark. The Medical Society also opposes the granting to the
Attorney General’s office the authority to file Ch. 93A claims against those
health care providers who contribute to exceeding the benchmark, as in H. 619
and H. 2218. The Medical Society believes that the authorities currently laid
out in Massachusetts law are sufficient, and have largely been proved
effective.
Lastly, the Medical Society wishes
to point out that the reduction in the Health Care Cost benchmark by the Health
Policy Commission this year further contribute to the lack of a need to support
strengthening the HPCs authorities. The reduction in the benchmark will allow
for more health care organizations to be subject to the existing tools of the
Health Policy Commission, and the Medical Society urges the legislature to
continue to allow HPC to make use of them, but to not expand such authorities,
again given the reduction in the benchmark. The Medical Society also wishes to
note that increases in authorities of regulators come at price to the health
care organizations. Physician organizations are continuously asked to increase
reporting to health plans, to public payers, and to other government
organizations. These requests for data, from HPC and elsewhere, take time and
resources.
The Medical Society also
believes that the current assessment structure for payment into the Community
Hospital Reinvestment Trust Fund has been thoughtfully established by the
legislature, and should not be amended, as
suggested in H. 2986/S.644 An Act
benefiting the community hospital reinvestment trust fund.
The Medical Society thus
urges the legislature to leave authorities of the Health Policy Commission, and
the structure of the Community Hospital Reinvestment Trust Fund, unchanged, and
to oppose the aforementioned bills.
