The Massachusetts Medical Society appreciates the
opportunity to provide comment to the Health Policy Commission regarding the
2018 Health Care Cost Benchmark. The Medical Society strongly supports the
intent of Chapter 224, and the mission of the Health Policy Commission to
develop policy to reduce health care cost growth and improve the quality of
patient care. The Medical Society adopted formal policy committing the Society
to “partner with other stakeholders to address system-wide mechanisms to
control the forces responsible for the escalation in health care costs.” The
Medical Society strongly supports thoughtful policies to drive sustainable
containment of health care costs below the benchmark on an ongoing basis-
whether at 3.6% or 3.1%.
The Medical Society wishes the urge the Health Policy
Commission to retain the 3.6% benchmark that has served well from 2013-2017. While
we hope that many ongoing cost containment strategies will lead to reducing
year-over growth to even less than 3.1%, we offer the following comment to
explain our preference of retaining a 3.6% benchmark.
First, the current uncertainty about the payment and
delivery of health care in Massachusetts warrants greater flexibility in the
benchmark. External variables such as the attempted repeal and replace of
Affordable Care Act as well as broader uncertainty about Medicaid funding and
the Commonwealth’s 1115 waiver all point to the need for greater flexibility in
a benchmark to account for many significant factors beyond the control of those
that are held to the benchmark.
Second, while the benchmark continues to serve as a vital
metric to inform broad policy discussions, such as those articulated at the
Health Policy’s Cost Trends Hearings, many vulnerabilities of the metric which
have been discussed at length over the past years point toward not reducing the
benchmark. Until a more precise metric is enacted that takes into account
expansions in access, coverage, and care as an important positive feature of
health care change, this metric should not be reduced- especially when
expanding access and providing care to more individuals will result in more organizations
being potentially exceeding the benchmark.
In addition, the broad nature of the metric- which does not
take into account sector analysis- also warrants additional flexibility in the
actual benchmark rate. The Medical Society has observed continuous sector
analyses in HPC cost trends reports which show physician spending to be stable
over time, including showing a 1.9% growth in commercial spending for
professional physician payment from 2013-2015. During these same times, we have
seen prescription drug pricing and utilization increase substantially. The
Medical Society again underscores the importance of continuing to engage on and
analyze these important issues, all while keeping the benchmark at the level
that has served the Commonwealth well over the past several years.
Third, while the benchmark is most often associated with the
subsequent policy discussions and analyses, the ultimate consequence of a shift
in the benchmark is the number of providers and payers that could be subject to
Performance Improvement Plans. The regulations for the Performance Improvement
Plans are new, and it is likely they will be enforced more in the future.
Performance Improvement Plans create significant administrative burden for
physicians, and the administrative toll of providing information for these
inquires, and the potential burden of creating and complying with Performance
Improvement Plans cannot be understated. The Medical Society questions what
benefit will really be gained by reducing the benchmark to 3.1%? Are providers
and payers with increasing cost growth year-over by 3.1% to 3.6% really the
intended target for Performance Improvement Plans? Retaining the 3.6% benchmark
will continue to allow the Health Policy Commission the authority to monitor and
approve Performance Improvement Plans for the entities most responsible for
driving up cost growth in Massachusetts.
In conclusion, the Medical Society strongly supports the
mission of the Health Policy Commission, and we remain committed to
collaborating on thoughtful policies to inform a sustainable health care
delivery system in Massachusetts. Success is cost containment is vital to
ensuring sustainable access to care for all patients in the Commonwealth. The
Medical Society believes these aims are best pursued with the flexibility of a
benchmark of 3.6%.
