- The size of businesses that would face the House insurance assessment may be too small (ten or less employees). Businesses of 50 or more employees would be better able to afford a health insurance benefit for their workers.
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- An enhanced, simplified reform of the Insurance Partnership, that we call “Health Care Plus”– subsidizing employers of up to 75 eligible workers and subsidizing eligible employees may be more appropriate for small business rather than House proposal to require employer contributions to the Commonwealth Care Fund with ten or more workers since the assessment could constitute a substantial burden to such businesses, including many entrepreneurial businesses, that are a key to the overall economic success of the state. Consideration might also be given to allowing non-profit health care employees or other human service workers earning below 300% of FPL guidelines to obtain subsidized health insurance, without the comparable subsidy for the employer because of the public service provided by their work.
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- The final health plan should include an investment, of at least $5 million, in the state’s e-Health initiative to help community hospitals and health centers invest in technology the streamlines patient records and prescribing of medication in ways that improve safety and quality while reducing cost.
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- The House proposal for the Commonwealth Health Insurance Connector is intriguing, although we want to discuss whether the Group Insurance Commission is the most appropriate agency to administer this program and we believe that any such program should build on existing successful insurance intermediaries in the private sector rather than expanding or creating state bureaucracy.
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- If a Commonwealth Health Insurance Connector is to be established it should require that all credentialing of hospitals, physicians or other providers be simplified and uniform so that any administrative burden for providers in minimized.
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- Review whether there may be a need for a reinsurance program to support low cost health premiums in order to minimize the amount required for deductibles or co-payments.
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- Review existing mandated health insurance benefits to determine by a cost-benefit analysis whether they should continue to be required of existing insurance plans, and place a moratorium on any new benefits pending such a review.
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- A study of the Community Health Outreach Worker Program, as the House proposes, appears to be inadequate given previous success of such an outreach worker program. There is growing evidence that there would be significant benefit in establishing a patient navigator program to help those vulnerable populations eligible for enrollment in Mass Health or in low cost or subsidized insurance plans to eliminate health disparities and remove language and cultural barriers to health access and health care delivery. The establishment of an Office of Health Disparities within the Department of Public Health to focus on the issue of inadequate access to care and substandard care delivery for women, minorities, and residents of underserved remote geographic regions of the Commonwealth should also be considered.
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- The extraordinarily low level of MassHealth (Medicaid) reimbursement for health care providers should be addressed in any reform plan. The low reimbursement rates create cost-shifting to private employer-based and individual health insurance forcing higher premiums for those now insured and, in some cases, denying access to care in some specialty areas such as mental health. A provider payment formula similar to the Medicare program would simplify administration and be more equitable.
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- Much more attention is needed in providing improved quality and patient safety than appears in the House plan. A stronger pay for performance provision with good patient outcomes linked to reimbursement for services should be part of any good health care reform legislation.
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- More discussion is needed about the value of
mandate-lite health insurance plans of $140/month premiums as the House plan proposes, or $200/month plans as the Governor has suggested in order to demonstrate that these plans offer regular access to primary care and prevention without deductibles and co-pay rates that discourage utilization of providers for effective prevention and care management. Whatever low cost premium plan is finally offered, there should be a study of its effectiveness. Furthermore, no stripped down plan should fail to offer such basic health services as the Governor has proposed in his plan - Preventive and primary care; Emergency services; Surgical benefits; Hospitalization benefits; Ambulatory patient care; Mental health benefits; and Prescription drug coverage.
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- The expansion of MassHealth, as proposed in the House plan, would effectively utilize federal Medicaid funding for expanded health access, however, the state needs to make certain that these funds, as well as current Medicaid expenditures, are spent properly. The recent report on Medicaid fraud and abuse by the State Auditor should be addressed in any final health plan.
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- The reduction in Uncompensated Care Pool assessments on health plans and business proposed in the House plan needs to be accompanied by some assurance that the savings will be passed on to both employers and employees by reduced premiums. Furthermore, the UC pool needs to be retained at some reasonable level during the transition to full coverage that can be expected to take at least a year so that providers are not unduly burdened by legitimate free care demands.
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- With the well-established fact that our aging population will require more health care, it would seem prudent to include in any final health access plan the guidelines and incentives to encourage to purchase of long term care insurance that would support home care, hospice care, assisted living, and nursing home
care
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- The final plan should not miss the opportunity to improve the administration and delivery of public health through reform of the Public Health Council and restoration and expansion of public health prevention, infection control, and expanded consumer quality information.
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- Any final plan ought to recognize the inadequacy of the current medical malpractice system in resolving issues between providers and patients and address the added cost of malpractice insurance and defensive medicine, perhaps by establishing a pilot program such as “Sorry Works!” or other apology protocol such as now being used in the Harvard system.
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- Consider methods to provide relief for taxpayers with the growing cost of municipal health insurance premiums by such means as allowing municipalities the option of selecting Medicare Part B for local retirees and permitting all municipalities to bargain with individual employee unions or groups.
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- Given the growing body of evidence that extended work hours and sleep deprivation reduces the quality of health care and increases the chances of medical error, attention needs to be given in any final health access bill to development of staffing plans by health care providers for more rational work schedules for resident physicians, medical students, and nurses.
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- While use of the tobacco settlement receipts may well be an appropriate dedication of those funds, there should also be discussion of utilization of additional portions of the settlement to expand health prevention in a variety of areas and restore tobacco enforcement and cessation programs. An additional concern for state executive and legislative budget writers will be how to replace these funds that are currently supporting other General Fund appropriations.
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