An Act Providing Financial Transparency for Patients Receiving Care at Hospital-Based Outpatient Facilities
Joint Committee on Health Care Financing

The Massachusetts Health & Hospital Association (MHA) on behalf of our member hospitals, health systems, physician organizations and allied health care providers, appreciates the opportunity to submit comments in strong support of SB700, “An Act Providing Financial Transparency for Patients Receiving Care at Hospital-Based Outpatient Facilities.”

MHA supports providing complete transparency of patient financial obligations for services provided at hospital outpatient departments. In particular, hospitals believe that patients should be informed and fully understand those circumstances when a separate facility fee may be applied to a procedure or service. Hospital outpatient departments and hospital-based entities are required by Medicare to inform the patient and the public that a specific location is part of the main hospital and may therefore be billed as a hospital.

Facility fees enable hospitals to send specialists to underserved communities and allow those specialists to provide services without having to pay rent and overhead. Hospital-based clinics may provide more comprehensive services than a traditional medical office and offer services that are not otherwise available in the community to vulnerable patient populations. Physician offices and ambulatory surgical centers often do not provide services to Medicaid or uninsured patients, while hospital-based clinics accept all patients. It important to note that patients who receive services in hospital-based clinics are often too sick or complex for treatment in traditional medical offices.

This legislation establishes statewide transparency requirements consistent with Medicare standards (42 CFR 413.65). Under this bill, any hospital-based outpatient provider, prior to the delivery of non-emergency healthcare services, will be required to inform a patient that: it is licensed as part of the hospital and the patient may receive a separate facility fee charge in addition to and separate from the professional fee charged by the provider; the patient may incur financial liability that is greater than if the professional medical services were not provided by a hospital-based facility; and how the patient can find out information on the potential financial liability for known services through either the hospital or the patient’s insurance carrier, along with information that the actual liability may change depending on the actual services provided.

Thank you for the opportunity to offer comments on this important matter. If you have any questions or concerns or require further information, please contact Michael Sroczynski, MHA’s Senior Vice President of Government Advocacy, at (781) 262-6055 or msroczynski@mhalink.org