Massachusetts Medical Society: Testimony In Opposition to H. 591, an Act to Strengthen the Pip Process before the Joint Committee on Health Care Financing

Testimony In Opposition to H. 591, an Act to Strengthen the Pip Process before the Joint Committee on Health Care Financing

The Massachusetts Medical Society appreciates the opportunity to provide comment on a selection of bills aimed at amending the authorities and processes of the Health Policy Commission. The Medical Strongly supports and appreciates the role of the HPC in promoting policies that to contribute to reductions in health care cost growth and improvements to the quality of patient care. 

As the Medical Society acknowledges the unsustainable escalation of health care costs, we believe that the authorities granted to the Health Policy Commission in Chapter 224 of the Acts of 2012 are sufficient to thoughtfully promote cost containment in Massachusetts. While health care costs continue to provide challenges throughout the state, there are also many very positive signs in Massachusetts, including annual growth in commercial health insurance premium spending per enrollee in Massachusetts which has been roughly 2 percent per year since 2012, significantly below national trend through 2015.

The Medical Society believes that the authorities provided to the Health Policy Commission under Chapter 224 are appropriate, effective, and should not be altered at present. The cost benchmark, the Cost Trends Hearings, and other associated authorities of the HPC have driven discussion and increased transparency and accountability. Cost and Market Impact Reviews and Performance Improvement Plans also provide authority to the Commission to drive accountability and to promote cost containment for specific proposed transactions and for individual physician organizations, hospitals, and payers.

For these reasons, the Medical Society urges opposition to the H. 591, An Act to strengthen the PIP process; H. 617, An Act to prohibit material changes for above benchmark providers; H. 618, An Act strengthening market impact review; H. 619, An Act enhancing the market review process; and H. 2218, An Act relative to protecting health care consumer. The Medical Society does not believe that the authorities of the HPC should be expanded, and opposes a prohibition of material changes for organizations that exceed the benchmark. The current formula of the benchmark means that certain factors such as changes in patient population, increases in volume of patients, and changes in service line could all lead to increases in THCE, but may not be reflective of low value, costly care. Material changes should thus not be prohibited for organizations exceeding the benchmark. The Medical Society also opposes the granting to the Attorney General’s office the authority to file Ch. 93A claims against those health care providers who contribute to exceeding the benchmark, as in H. 619 and H. 2218. The Medical Society believes that the authorities currently laid out in Massachusetts law are sufficient, and have largely been proved effective.

Lastly, the Medical Society wishes to point out that the reduction in the Health Care Cost benchmark by the Health Policy Commission this year further contribute to the lack of a need to support strengthening the HPCs authorities. The reduction in the benchmark will allow for more health care organizations to be subject to the existing tools of the Health Policy Commission, and the Medical Society urges the legislature to continue to allow HPC to make use of them, but to not expand such authorities, again given the reduction in the benchmark. The Medical Society also wishes to note that increases in authorities of regulators come at price to the health care organizations. Physician organizations are continuously asked to increase reporting to health plans, to public payers, and to other government organizations. These requests for data, from HPC and elsewhere, take time and resources.

The Medical Society also believes that the current assessment structure for payment into the Community Hospital Reinvestment Trust Fund has been thoughtfully established by the legislature, and should not be amended, as
suggested in H. 2986/S.644 An Act benefiting the community hospital reinvestment trust fund.

The Medical Society thus urges the legislature to leave authorities of the Health Policy Commission, and the structure of the Community Hospital Reinvestment Trust Fund, unchanged, and to oppose the aforementioned bills. 

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