Joint Committee on Health Care Financing
The Massachusetts Health and Hospital Association (MHA), on behalf of our member hospitals, health systems, physician organizations, and allied healthcare providers, appreciates the opportunity to submit comments regarding legislation on pharmacy, oral health and chronic disease management.
MHA supports
SB653, which eliminates co-payments for all prescriptions and devices used for the treatment of chronic illness. Research has shown that increased cost sharing, especially in the course of treatment of chronic illness, serves as a barrier to patients who are seeking care and non-adherence to medication regimens. Even relatively small co-payments have been associated with lower rates of seeking preventive services and co-payments for treatment of chronic illness would only hinder the treatment’s rate of success. While the Affordable Care Act eliminates cost-sharing for preventive services, it does not do so for prescription drugs and devices used to manage chronic illness. In this era of the accountable care organization and increased consumer responsibility for their own care, it makes eminent sense to eliminate chronic illness cost-sharing. Results of programs that have eliminated co-payments for the treatment of chronic illnesses (such as diabetes) illustrate that lower health care costs are possible by reducing barriers to the use of preventive medications and increased compliance by patients. Businesses that have reduced co-payments for chronic medications for their employees have seen up to a 14% reduction in non-adherence. MHA respectfully urges the committee to add language to this bill to prohibit insurance carriers from passing the cost of the co-payments/deductibles on to health care providers and/or suppliers by reducing the overall reimbursement rate for services provided by the amount of the co-payment or deductible.
MHA supports
HB624, which seeks to set up a pilot program to enhance management of early childhood caries among MassHealth patients. Although cavities and tooth decay are largely preventable, they remain the most common chronic disease of children and adolescents. Cavities and tooth decay impact child health and development and lead to unhealthy adult teeth and high costs for dental treatment throughout life. The pilot program established through this bill seeks to introduce more frequent preventive visits for high-risk children, fluoride treatments, and enhanced patient education in order to reduce the number of children with new cavities, reduce referrals for oral surgery and create cost savings in the MassHealth program.
MHA opposes section 3 of
SB652 which substantially mirrors
SB655 which is also before the Health Care Financing Committee. These provisions would increase the current financial penalties placed on providers and payers who fail to submit documents, without just cause, to CHIA within certain designated time. It also allows, but does not require, CHIA to define “just cause.” While the section may be well-intentioned, it fails to recognize that many entities often request and are granted an extension by CHIA to file reports at later time periods due to differences in corporate fiscal years that delay issuance of reports and federal filing dates that are also different from the state. Such unintended consequences should be carefully reviewed by the Committee.
HB594 would direct the office of Medicaid to establish a bundled payment pilot program to serve those with complex conditions and co-morbidities, including behavioral health conditions. The bill requires the program to be designed on the four models of care included in the “Bundled Payments for Care Improvement Initiative” of the federal Centers for Medicare and Medicaid Services. MHA has significant concerns with certain elements mandated by the bill, particularly the establishment of bundled payment that includes a discount from “usual hospital inpatient payments.” It is unclear how such a requirement fits into a government-run program like Medicaid, where payments already fall fare below the cost of care.
MassHealth is already implementing payment reform options, including those through Accountable Care Organizations (ACOs) that will be going into effect later this year. In fact, in its public stakeholder session “Creating a Sustainable MassHealth Program” in April of 2015, MassHealth stated part of its payment reform framework would include “bundled payments for certain high spend areas.” Such efforts are very complex and will take considerable collaboration, time, and resources to develop. MHA believes the Baker Administration and MassHealth are wholeheartedly pursuing these concepts as they implement the current MassHealth ACO program. Therefore, while this bill has merit, we do not believe
HB594 is necessary to achieve its intended outcome.
MHA opposes
SB662 which eliminates coverage for prescription drugs from the definition of minimum creditable coverage (MCC). Massachusetts health reform has been a success due in part to the establishment of appropriate MCC standards and enforcement of those standards. Setting adequate standards for “creditable” plans helps guarantee that insured individuals have access to needed medical care. MHA believes that the state has developed balanced coverage decisions that recognize the health needs of Massachusetts residents and takes into account the economic realities facing the Commonwealth and its employers.
Thank you for the opportunity to offer comments on this important matter. If you have any questions or require further information, please contact MHA's Vice President of Government Advocacy, Michael Sroczynski, at (781) 262-6055 or
msroczynski@mhalink.org.