The Massachusetts Medical Society appreciates the opportunity to offer further remarks on the level of risk which provider groups may take on and still not reach a threshold which makes full certification necessary. As we noted in our remarks dated September 28th, there are many diverse models of payment and care delivery in Massachusetts. Our discussions with a wide range of provider groups, both large and small, have reinforced that perception. Risk models vary with some groups surviving on models which include full risk and others unwilling to go beyond 20% total risk.
The MMS recognizes the Division's unwillingness to establish tiers of risk bearing certification. However, after our review of the market it is clear that the amount of risk any group may take on varies with their resources, their experience, the size of the group, the region they represent and the particular patients assigned to that group. Other factors would also include whether reinsurance programs are available to the group.
The MMS urges the Division to take a broad view of the providers for whom risk will not impact access to patient care. . After all, few if any groups have experienced bankruptcy or cancellation of contracted services for patients in the last twenty years. In light of this stability, the Division should proceed carefully, not be prescriptive but flexible and avoid adding damaging actuarial costs that may impact sustainability, to practices in no need of such reviews.
While insurers have stated the need to require all risk bearing groups to incur the costs that insurers bear in the Commonwealth, it is important to note that the legislature appears to have wanted to encourage new models of payment for a wide variety of large and small providers. The legislative vision includes global payments in virtually all practice settings. We recognize that patients and costs are not served by limiting most providers to fee for service contracts or to joining a small number of provider organizations, likely with more resources to meet requirements similar to those for insurance companies.
The MMS urges the Division to look at the significant risk many groups take on now with the alternative quality contract and similar models and devise regulations which protect the public without subjecting providers to expensive procedures simply to be eligible to compete for new models of payment.
