The Massachusetts Health & Hospital Association (MHA), on behalf of our member hospitals, health systems, physician organizations, and allied health care providers, appreciates this opportunity to offer comments on bills that seek to address health and dental insurance matters.
MHA supports the general approach to healthcare provider performance assessment contained in HB2183. MHA’s own principles for measuring, reporting and improving the quality and safety of healthcare emphasize the following:
- The methods and data used in evaluations must be completely transparent. All data and information about the analytical methods – including micro-level detail – must be applied to organizations that are being evaluated so that independent analyses and validation of the data and analytical methods may be conducted in advance of the release/use of the information.
- Evaluations of the quality of care used to inform the public, to make purchasing decisions, or to reward/sanction organizations must rely on a complete clinical picture of the patient and the care delivered. Administrative or billing databases are known to provide an incomplete picture of the care delivered and may also contain erroneous information. Requiring prior review of the data by the provider being measured is one way to identify and remove incomplete or erroneous data so that the public is not misinformed and the provider is treated fairly.
- Differences in measures across providers that are not statistically significant and clinically meaningful should not be portrayed to consumers as grounds for making health care decisions.
- Organizations that assume a responsibility to inform the public about the quality of care have a responsibility to identify the limitations of their measures and methods, and to accompany publication of its own analyses with responsible challenges to, alternate analyses of, or other explanations of their findings.
MHA and the insurance companies in Massachusetts have worked together on developing a common measure set for health insurers to use in hospital quality tiering in order to promote simplification and consistency in measure sets across all products – these measures are part of the standardized quality measure set. MHA supports and encourages this approach for physicians as well. MHA also supports uniform tiering for all providers in a practice to reduce administrative burdens for practices and confusion for patients and DOI oversight to insure adequate networks and access to providers in the lowest cost sharing tier for all covered services.
MHA additionally supports HB495. In order to align and coordinate quality measures across all payers, this bill would require health insurers, the GIC and MassHealth to limit the use of quality measures used for pay- for-performance payments to those in the statewide quality measure set. The statewide quality advisory committee (SQAC) is also given more flexibility in creating the standard quality measure set (SQMS) as the new language in HB495 includes may (instead of shall) “consist of a specific list of quality measures.” The legislation further requires CHIA to update the website more frequently and empowers the SQAC with the authority to provide the standard quality measures to be posted and verified on CHIA’s website.
MHA opposes HB2157/SB565. This legislation moves in the exact opposite direction of Massachusetts health reform and takes apart the merged insurance market by removing eligible individuals and putting them back into the non-group health insurance marketplace. Since merging the individual and non-group markets essentially lowered health insurance premiums for individuals and raised them for small businesses, taking them apart would likely have the opposite effect, thereby increasing health insurance premiums for individuals and probably making the non-group market more volatile. Given the uncertainty with the Affordable Care Act and the potential destabilization of the market, this is no time to be dismantling the merged market. Therefore, MHA urges great caution when addressing the provisions of HB2157/SB565.
MHA also opposes SB595. This bill would allow eligible individuals to purchase short-term medical plans – typically less than 12 months long. Once the plan ends, it would be considered a qualifying event and the person would be eligible to seek additional insurance coverage through the state’s insurance exchange. While such short-term insurance plans may be stopgap measures for a consumer who has no insurance, it’s not clear from this legislation that these plans will have to meet minimum creditable coverage standards or who will be able to offer them. Short-term plans will make it much harder for providers to track coverage of patients, file claims and get paid (particularly if these are out of state carriers). In summary, such plans will be administratively more burdensome and lead to an increase in underinsured individuals.
MHA opposes HB538. This legislation amends health insurance statutes to specify which metrics may and may not be used in determining alternative payment arrangements. It additionally permits the use of age, acuity, social determinants of health, and behavioral health needs, while prohibiting the use of historic price trends among categories of users or use of particular providers. It would additionally require the disclosure of data used in pricing determinations. And finally, it establishes that use of prohibited data or failure to disclose data to the Center for Health Information and Analysis is to be considered an unfair business practice under GL 93A. While the state’s Provider Price Variation Commission did not weigh in on this proposal, MHA opposes this legislation since it would be administratively complex to administer and does not take into account numerous nuances in provider prices. Such a proposal would need to be modeled and tested significantly before being considered and implemented.
Thank you for the opportunity to offer testimony on these issues. 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 firstname.lastname@example.org.