Joint Committee on Financial Services
The Massachusetts Health & Hospital Association (MHA), on behalf of our member hospitals, health systems, physician organizations, and allied healthcare providers, appreciates the opportunity to submit comments on the following bills regarding health insurance. MHA supports the general approach to healthcare provider performance assessment contained in SB558. Our own principles for measuring, reporting, and improving the quality and safety of healthcare emphasize the following:
- Methods and data used in evaluations must be completely transparent. All data and information about 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 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 healthcare decisions.
- Organizations that assume a responsibility to inform the public about the quality of care also have a responsibility to identify the limitations of their measures and methods, and to accompany publication of their own analyses with responsible challenges to, alternate analyses of, or other explanations of their findings.
MHA and Massachusetts insurance companies 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 across all products. These measures are part of the standardized quality measure set. This is an approach that we would support and encourage for physicians as well.
Additionally, MHA supports the recommendations from the state’s Special Commission on Provider Price Variation that endorsed the need for improved transparency regarding health plans’ provider tiering. We believe that these recommendations would also be useful for physician practices. Regarding tiering display, the commission endorsed health plans developing a uniform method for displaying a hospital’s assigned benefit tier so that information on how the hospital performed on cost and quality benchmarks is presented in a consumer-friendly format for patients and providers. Regarding tiering transparency, the commission requested that, upon a request by a hospital, health
plans should provide the methodology used for a hospital’s tier placement, including the criteria, measures and data sources, as well as hospital-specific information used in determining the hospital’s quality score, how the hospital’s quality performance compares to other hospitals, and the data used in calculating the hospital’s cost efficiency.
MHA opposes HB972, which would repeal language that prohibits insurer contract terms to require providers to participate in new select or tiered network plans without the right to opt-out of the plan. MHA strongly opposes removing the opt-out provision from statute, which would eliminate the ability for providers to fairly negotiate with health plans by forcing them to participate in any tiered or limited network plan created by a carrier. It would create an inequitable situation and give complete control to carriers by removing the only stipulation that protects providers. In addition, providers could be “stuck” in a product if the carrier reclassifies them to a higher tier. While they could appeal the decision, they would not be able to opt out of the product if the tier classification ultimately stands.
MHA opposes SB551, which would remove the current requirement for health plans and utilization review organizations to notify providers by telephone and follow up with written or electronic confirmation within two working days for both approved initial determinations and approved concurrent review. MHA opposes removing these requirements, as providers and patients would have no written documentation of the services that were approved.
Thank you for the opportunity to offer testimony on this matter. If you have any questions regarding this testimony, or require further information, please contact Michael Sroczynski, MHA's Senior Vice President of Government Advocacy at (781) 262-6055 or firstname.lastname@example.org