Comments Regarding Center for Health Information and Analysis Proposed Methodology For Referring Health-Care Entitites to the Health Policy Commission

The Massachusetts Medical Society appreciates the opportunity to provide comment to the Center for Health Information and Analysis regarding the proposed methodology for referring health care entities to the Health Policy Commission. The methodologies proposed by the Center will be used calculate which health care entities, including physician organizations, will be referred to the Health Policy Commission for formal inquiry into whether a Performance Improvement Plan is necessary to hold the entity accountable for increases in total medical expenditure which may contribute to the state exceeding the health care cost benchmark. We appreciate the transparent process, and understand the charge to fulfill the underlying statutory obligation. We offer the following comment to improve upon the proposed methodology.

The Medical Society strongly opposes the provision of the proposed methodology that includes a pathway that considers physician organizations that do not exceed 100% of the cost benchmark. The statutory charge put forth in Section 18 of Chapter 12C requires CHIA to put forward a list of providers whose increase in health status adjusted total medical expenditure (HSA TME) “is considered excessive and who threaten the ability of the state to meet the healthcare cost growth benchmark.” This is a two-part requirement, and the second part is predicated upon the health care entity contributing to the state exceeding the health care benchmark. We believe this implies only those physician groups over 100% of the benchmark should be considered in this methodology as health care entities as considering those less than 100% of the benchmark is inconsistent with the intent of the legislature. We therefore strongly urge the removal of the HSA TME ≥ 85% of the benchmark from the methodology.

If this route is retained, however, we provide the following comments:

Methodologies must be amended to allow for a less select patient group to be evaluated. At present, too many patients are not included in the methodology, primarily those in non-HMO-like products. This disadvantages physician groups that have shifted larger proportions of their patients to risk-based contracts. This means that physician groups taking on more risk, often at the urging of regulators and with the intent of helping combat the state exceeding the cost benchmark, are judged by a smaller proportion of their patients and are more likely to be subjected to skewed calculations.

We further share concerns that the lack of “per capita” HSA TME calculations could allow for calculations that do not reflect value or efficiency of care, but instead are penalized for expanding scope and access to care. As discussed at a macro-level at many Health Policy Commission meetings and hearings, this would not be consistent with what many believe is the spirit of the law which is to promote increases in value and to support expanded access to quality medical care.

The Medical Society additionally notes concern that some calculations could be too narrow to identify truly material increases in HAS TME that warrant further investigation by the HPC. We have noted suggestions put forward by other stakeholders in the past about the shortcomings of year-over trends, when often a longer-term view would be more appropriate. Any strategies to increase the overall scope of calculations to get the most accurate understanding of HSA TME would help improve the implementation of the law.

The Medical Society strongly believes that CHIA must serve as a strong gatekeeper in determining which health care providers will be subject to inquiry by the Health Policy Commission for being determined as being considered “excessive and who threaten the ability of the state to meet the healthcare cost benchmark.” The performance improvement plan inquiry process can be an expensive, resource heavy process; it should be reserved for only the entities that really warrant such inquiry.


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