The Massachusetts Medical Society (MMS) appreciates the opportunity to testify before the Joint Committee on Financial Services in strong support of H.931 An Act Promoting High Value and High Quality Care.
Physicians in the Commonwealth of Massachusetts remain committed to driving the highest quality, highest value care to all patients. As depicted in the appendment to this written testimony, the growth in spending on physician services has been minimal; physician-led Accountable Care Organizations (ACOs) have saved 23% on spending per patient when compared to academic medical center-anchored ACOs; and the rate of total health care expenditure year-to-year growth has decreased, remaining well below the benchmark for such spending growth. Despite this progress in cost containment, physicians’ ability to further curb health care costs is impeded by unnecessary administrative complexity and challenging policies promulgated by payers and government. Such hurdles limit the effectiveness of physicians’ attempts to achieve the goals of providing high-value and high-quality care to patients in Massachusetts.
The Medical Society believes that H.931 addresses many of the barriers in the way of realizing those goals. Spending on prescription medications is one of the highest growth areas in health care spending, with a 4.1% increase in 2017, as compared to an overall increase of 1.6% in Total Health Care Expenditures (THCE). This bill requires a wider and deeper investigation into prescription drug costs, specifically authorizing the Health Policy Commission (HPC) to hear testimony regarding prescription drug costs and price increases at their annual cost trends hearing, while also requiring pharmacy benefit managers to testify at those annual hearings. This bill further broadens the scope of the information to be considered in the HPC’s annual reports. Through this bill, important perspectives and data will be gathered and analyzed such that evidence-based approaches can be formulated to help contain the cost of health care through precise and directed manners aimed at therapeutic and cost-effective utilization of prescription medications.
Similarly, H.931 would require the Center for Health Information and Analysis (CHIA) to investigate the overall costs of health care related to prescription medications by promulgating regulations to ensure uniform analysis of information relating to pharmaceutical manufacturing companies and pharmacy benefit managers (PBMs). H.931 authorizes CHIA to collect data from pharmaceutical companies and PBMs related to wholesale acquisition costs, research and development costs, marketing and advertising expenses, etc. CHIA would be required to consult with pharmaceutical companies and PBMs before adopting these regulations and would develop a process for reporting health care prices and information from providers for use by consumers, employers, and other stakeholders. Overall, the transparency in prescription drug prices required by this bill would serve to the benefit of consumers and regulators by removing some of the mystery of health care costs and pricing, allowing for a balanced analysis that would be able to guide how to best address these growing expenses.
This bill also addresses the burdens associated with administrative complexity, which contribute significantly to increasing overall health care costs. Physicians can often find themselves being evaluated on dozens of different quality measures, as each health plan and product may require slightly different quality measures. The process of achieving quality measure alignment allows for identification of the most relevant quality measures while reducing administrative burdens associated with reporting on many different measures. The Medical Society strongly supports comprehensive quality assessment and has long been concerned with the proliferation of related, redundant quality measures that have increased the burdens of reporting without meaningfully improving quality assessment. In establishing a standard set of measures for health care provider quality and health system performance, this bill would ensure consistency in the use of quality measures and improve the monitoring and oversight of health systems, thus simplifying the administrative complexity resulting therefrom.
H.931 further also promotes the use of telemedicine. This provisions regarding telemedicine in this bill are consistent with the approaches regarding telemedicine proposed in H.1002 An Act Relative to Expanding Telemedicine Services and H.991/S.612 An Act Advancing and Expanding Access to Telemedicine Services. The Medical Society supports those bills and the provisions in H.931 regarding parity in insurance coverage for and reimbursement of telemedicine services, which will help to promote high-value, high-quality relationships between patients and physicians. Telemedicine can increase quality and efficiency by reducing no-show appointments, improving care coordination, and expanding access to behavioral health services; however, telemedicine cannot thrive in Massachusetts without adequate coverage and reimbursement. This bill addresses those concerns by establishing parity in coverage for care that can be appropriately provided via telemedicine, which is necessary to correct inequities in access to care.
This bill also addresses out-of-network billing practices by providing a solution that removes patients from obligations regarding these bills. Rather than continue to allow patients to be charged in these instances of unavoidable out-of-network covered services, this bill establishes a system for payers to reimburse physicians directly based upon a set formula. Through this process, patients would be protected from surprise bills, and physicians would be appropriately compensated for services they rendered to those patients.
Furthermore, this bill promotes high-value, high-quality care by authorizing physicians to dispense pharmaceutical medications from their offices. This authorization allows physicians to offer patients an opportunity to avoid intermediaries that add to the expense and reduce convenience of health care. Such a change will help to promote medication adherence and prompt efficient treatment by helping to foster a more direct furnishing of health care to patients in need, further bolstering the doctor-patient relationship. We believe that provisions such as this will allow for physicians to promote innovative practices designs which can benefits patients with both added convenience and reduced price. This is a tact taken by many states across the country and has yielded important cost benefits.
Finally, this bill addresses some important protections that promote improvements in care. Firstly, the bill provides important peer review protections to ACOs. These protections, which are already afforded to hospitals and physician organizations, are imperative to facilitating honest conversations about quality improvement. The Medical Society understands that medicine is a realm of continual learning and values these candid discussions that lend to improving patient care. Accordingly, the Medical Society strongly supports protecting peer review in ACO settings. Additionally, this bill strengthens a provision of the disclosure, apology, offer, and acceptance laws by clarifying that payments made as the result of this process need not be reported as malpractice settlement payments.
The Medical Society requests the legislature to take a critical look at containing the costs of health care by encouraging transparency in cost and pricing data and by reducing administrative complexity that results in growing costs unrelated to direct patient care. Accordingly, the Medical Society urges the Joint Committee on Financial Services to report out favorably on H.931 An Act Promoting High Value and High Quality Care.
