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Hospital Price Transparency Took Effect New Year’s Day
But, Where is it?

January 5, 2021 By

Happy 2021!!!

In this brand-new year, imagine that you have found your most desired showroom vehicle at a local dealership. After haggling with the salesperson (and the backroom manager), a process that is similar to playing ‘Let’s Make a Deal,’ you are handed the following purchase agreement that reads (in short):

This negotiated price is an estimate only and is not a quote or a guarantee of the amount that you will eventually owe…

Now wouldn’t that be a twist on the old way of doing things! But in healthcare, this is precisely the norm.

Recent Ruling on Hospital Transparency Pricing

On Tuesday, December 29, the U.S. Court of Appeals for the District of Columbia circuit rebuked the hospital industry’s legal attempt to banish new rules on price transparency from taking effect on New Year’s Day. I have written about the new rules frequently in the past. The price transparency rule, published in November 2019, was pushed by President Trump and HHS Secretary Alex Azar.

As it now stands, barring a President Biden ‘stay of execution’ order to relax these rules, hospitals must post their negotiated rates online beginning January 1, 2021. The online rates must be conveyed in a machine-readable format and also list their negotiated rates for at least 300 shoppable services in a consumer-friendly format – including 70 services picked by the Centers for Medicare and Medicaid Services (CMS).

Starting Jan. 1, 2022, health plans and insurance companies will have to provide a publicly available, updated data file on costs. By January 1, 2023, payers, such as commercial insurance companies and large, self-funded employer health plans will also need to comply with similar price transparency rules demanded of hospitals. This was discussed in my November blog, “Finalized Price Transparency Rules for Insurers.”

Not surprisingly, the American Hospital Association is disappointed by this latest decision and, according to their General Counsel, Melinda Hatton, “…are reviewing the decision carefully to determine (our) next steps.”

It’s Now 2021 – Have These Rates Been Posted?

On January 2, I’m sitting at my computer attempting to discern what actions a few Central Iowa hospitals have taken to comply with this new requirement to inform Iowan’s about specific ‘negotiated’ health prices, not just merely ‘estimated’ prices. Estimations, I might add, are simply playing a game of horseshoes and hand grenades, providing just enough information to check boxes to ‘inform’ an already confused public.

Below is a rather quick assessment of three Des Moines-area hospitals – in addition to the Iowa Hospital Association – and what they have listed on their websites as of January 2, 2021. Since that date, any changes made by the following organizations have not been reflected in my comments found below.

MercyOne – Des Moines

As I understand the requirements, MercyOne’s ‘Estimate Your Costs’ webpage does not conform with the new regulations on hospital price transparency. This webpage allows one to download a list of their ‘standard charges’ (in Excel format), but does not provide the ‘negotiated’ rates by payer. MercyOne cautions that this information is only a ‘partial estimate,’ as it does not include other fees beyond hospitals charges, such as “physician fees, charges for your emergency room physician, radiologist or anesthesiologist”.

Before an interested patient can gain access to “generate the most accurate estimate for your health care procedure,” one must click “Estimate Your Costs” and agree to the ‘Disclaimer’ before providing your name, DOB, type of desired medical procedure and your insurance vendor. I attempted to complete this exercise but was met with ‘an error’ both times.

Just as troubling to me is this disclaimer: “Benefits and eligibility are subject to change at any time. This estimate may contain private information that is protected by law. If you are not the patient, patient representative or guarantor, sharing, copying or using this information in any way is against the law.”

Frankly, I thought this regulation was all about ‘transparency’ of negotiated medical prices. If I want to publish what MercyOne has negotiated with any particular payer, I should be able to do so. I will assume this site has not been adequately updated and, consequently, this language requires a revision.

UnityPoint Health – Des Moines

The Patient Charges and Costs webpage for UnityPoint Health appears to be helpful, but when looking more closely, it has not changed to reflect the new regulation. The UnityPoint site refers to the January 1, 2019 requirement that hospitals list their ‘standard charges’ of Diagnostic-Related Group (DRG) charges. This information should be deleted from the website as it no longer is compliant with the new regulations. UnityPoint Health cautions the patient to ‘first contact your insurance provider’ who may provide their own ‘estimates’ for out-of-pocket costs based on the insurance plan of the patient. But doing so will likely invite the patient to enter a new labyrinth of confusion that is full of disclaimers, etc.

UnityPoint’s ‘Financial Estimate‘ webpage requires completion and submission before releasing prices. I did so, but when it was submitted, I received the following message: “Thank you for your request.  We’re striving to provide an easier and more personal way for you to plan your health care. A UnityPoint Health financial representative will reach out to you within 2 business days to provide your estimate information.”

This website is both confusing and non-compliant – based on my review date (January 2).

Iowa Hospital Association (IHA)

After a cursory review of the IHA website, there are no specific updates that provide revised information about this latest regulation.

Broadlawns Medical Center – Des Moines

With Broadlawns, we actually have a BINGO!

Two days before the required posting of negotiated rates, Broadlawns posted their ‘Pricing Directory’. Broadlawns provides this information in two formats: PDF file and CVS file. The 450-page PDF has the following disclaimer at the top of the first page:

This is an estimate only and is not a quote or a guarantee of the amount that you will owe or what the charges for services will be. The actual charges may be lower or higher than the estimates depending upon many factors – including actual services rendered, complications, your particular health care needs, and your actual insurance policy coverage.

The 450-page PDF includes 15 health insurance products offered by eight insurance companies: Aetna, CIGNA, Coventry, Health Partners, Medica, United Healthcare and Wellmark. Many shoppable services are broken down by professional (physician) and hospital services. You will find the procedure code, gross amount of the service, cash discount offered, negotiated rate with that particular insurer, and the minimum and maximum charge.

Out of sheer curiosity, I did a quick price comparison between Wellmark PPO and United Healthcare PPO for a few random procedures at Broadlawns (found below). Please note, this comparison does not suggest that these negotiated prices are the same at other hospitals. This information is only specific to Broadlawns Medical Center.In lieu of searching for the correct procedure code and shoppable services at Broadlawns, the patient can request a ‘Personalized Price Estimate’ from Broadlawns using the web-based Cost Estimator Request Form (or by calling a Broadlawns financial representative).

Conclusion

Because each patient encounter is so unique and may require various procedures, caveats by hospitals are certainly understandable when quoting specific procedure code prices. There are MANY hurdles to full-blown price transparency that cannot be categorically described in this particular blog. One obvious hiccup is – just how much the patient has remaining on his/her deductible and out-of-pocket maximum to determine their personal liability for the procedure(s). The patient will need to toggle between the health provider for specific prices and with their insurance vendor on whether the service is covered by their plan and, if so, how much the patient will be liable to pay. Transparency in medical prices help, but clarity on how to use this transparency will be problematic until a new world of simplicity evolves.

Many experts agree that price transparency in healthcare will eventually be a valuable thing to have, but this particular requirement is merely a first step toward a ‘Marie Kondo’ approach that will hopefully clean up a very messy industry when it comes to pricing. Kaiser Health News just published an article about the implications of having transparent medical pricing for consumers.

I envision that enterprising third parties will take this newly-released public data and morph it into usable consumer-centric information that can be easily accessed through a smart phone app for the patient. In addition, innovative clinician tools can help health providers perform real-time cost/value trade-offs with the patient while ordering procedures and diagnostic tests that impact the cost.

Simplifying a complex system will take patience, time and a general willingness to invoke needed change.

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Filed Under: David P. Lind Tagged With: , , , , , , ,

New Trend or Passing Fad?
Telehealth Services

May 19, 2020 By

This blog is the SECOND in a new series regarding the ‘unintentional consequences’ of the COVID-19 pandemic. As our lives have been abruptly altered due to social distancing requirements – both at home and in the workplace – unplanned ‘disruption’ of previous normal activities could permanently replace sacred elements once believed to be unyielding to any change. But COVID-19 just may have dictated new approaches to how we live and work.

Thanks to the COVID-19 pandemic, social distancing and stay-at-home orders during the past two months have made it difficult to have a face-to-face meeting with our doctor(s).

But necessity is indeed the mother of invention, and thankfully, telehealth – using email, video conferencing, online patient portals and other technologies – was already being used by some providers to aid in the delivery of patient care, typically to the benefit of rural patients.

Telehealth has been around for quite some time – at least a few decades. But its relatively steady growth trajectory has been refueled by the COVID-19 virus, prompting enhanced usage that we have not seen before. Patients, both young and old, have found a new method to safely seek care. Cleveland Clinic, as one example, has reported that demand for virtual visits is up more than 1,000 percent since the start of the pandemic.

For the sake of simplicity, I will be using the term telehealth interchangeably with telemedicine. According to HealthIT.gov, telehealth is different from the term, telemedicine, “because it refers to a broader scope of remote healthcare services than telemedicine.” Telemedicine refers to remote clinical services, while telehealth goes beyond clinical services to also include non-clinical services, such as provider training, administrative meetings and continuing medical education. Any reference to telehealth, therefore, also includes telemedicine.

Prior to the pandemic, telehealth usage wasn’t widely adopted in healthcare for many reasons. To understand the push-pull of telehealth, we must first understand the perspectives from patients and their healthcare providers.

Patient Perspective

For patients, telehealth can provide value and benefits for many key reasons, including:

  1. Less time in the doctor’s waiting room.
  2. No need to take time off of work.
  3. No transportation time or parking hassles.
  4. Reduced risk of obtaining infection while at doctor’s office.
  5. Eliminate child or elder care issues.
  6. More affordable.
  7. Access to specialists.

Telehealth, it must be noted, is not the panacea for every health-related scenario. A medical emergency or a difficult case to diagnose will still require a visit to the doctor or hospital. Telehealth can include physical exams, but depending on procedures performed (e.g. blood drawing, biopsy, X-ray, strep test) the process is more limited. But for wellness-related interactions, such as common office visits and mental health consultations, telehealth can be an efficient interaction process. A sample telehealth consent form offered up by the Agency for Healthcare Research and Quality provides easy-to-understand insight for patients who pursue telehealth services.

Physician Perspective

Physicians and hospitals, on the other hand, are a different story – at least prior to the pandemic. Generally, in the pre-COVID past, providers did not receive higher pay when using telehealth care, and most of the time, they received less pay for telehealth care when compared to in-office care.

With telehealth services, doctors would have to do essentially the same amount of work regarding time spent with the patient and documentation requirements, all while learning a new workflow to interact and treat patients. For this, the doctor is paid less for their time – something that few of us would want to experience in our own jobs.

Telehealth usage prior to the pandemic, therefore, struggled to quickly trend upward largely due to lack of payment parity with face-to-face office meetings. Without payment parity, telehealth did not see the growth gains that it currently has found under the current pandemic environment.

The value equation must also work for the health provider as it does for the patient.

Telehealth and the COVID-19 ‘Experiment’

With the advent of the virus epidemic, telehealth became an overnight ‘sensation’ for a few key reasons. To help providers experience telehealth as a value equation, Medicare is now paying for most visits and many private payers* waive virtual visit copayments, including Wellmark in Iowa. As of March 6, Medicare and some commercial insurers have said they will pay the same rate for video calls as for office visits.

*Some insurers have subsequently found, due to software problems, they are unable to immediately eliminate telehealth copays and cost sharing for millions of members. Additionally, carriers need consent from their self-insured clients to implement these policies.

Many states have relaxed, or deregulated, more stringent requirements for telehealth usage, including Iowa.  The Federation of State Medical Boards provides an updated listing of all states and their telehealth practices regarding COVID-19.

Stay-at-home orders offered legal risks if doctor offices and clinics stayed open and did not adopt telehealth services. Avoidance of legal risks and in-office infection, coupled with payment parity has made telehealth a tool for many health providers to finally embrace.

Going Forward

The value equation for both patients and doctors will be interesting to watch. When the virus finally simmers down and social distancing requirements are greatly relaxed, how will doctors react when their patients can safely return to visiting the doctor? Will the value equation for the doctor shrink from the heightened COVID period or will doctors look more long term on valuing physical distance for their own health, including staff members, and accept telehealth in the future?

Now that the genie is out of the bottle, will patients demand more telehealth services? Perhaps the patient experience during the COVID period will push patients to seek telehealth services elsewhere should their doctor reduce or eliminate the telehealth options in place during the pandemic.

How telehealth services are reimbursed from payers will certainly predict the future for telehealth. Will telehealth reimbursement to providers become more marginalized whereby payment parity is no longer being practiced by key payers? Perhaps payment parity becomes more prominent and, as a result, unleashes additional sophisticated telehealth services than what is provided today? Clearly, the opportunities are just as great as the barriers. The barriers can be difficult to accessing telehealth, such as absence of technology, digital literacy and reliable internet coverage.

The future of telehealth services looks extremely bright, but it will largely be dependent on how physicians view the value proposition of delivering this service to their patients. The COVID-19 pandemic may have provided the fortuitous nudge for telehealth to become a mainstream model of delivering healthcare to Americans. This will be a trend worth following!

Next Week’s Discussion:  Reliance on Drugs from Foreign Countries

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Filed Under: David P. Lind Tagged With: , , ,

COVID-19: What Will Happen to Future Private Health Insurance Premiums?

April 7, 2020 By

As of April 6, COVID-19 cases have surpassed 1.35 million globally, with more than 75,000 fatalities…and counting. The U.S. accounted for 367,000 infections and almost 11,000 deaths. The world economy is spiraling disastrously downward with no clear consensus when the bottom will be reached.

While watching the evening news recently, my wife asked me how insurance companies will remain financially sound if the scenarios of COVID-19 cases and fatalities reach doomsday projections. This is a logical, yet difficult, question worth some exploration.

In the U.S., most healthcare is privately provided – except for the elderly (Medicare) and for the poor (Medicaid). The key issue in the U.S. and most countries is to enable rapid testing of people in vulnerable populations, such as the elderly and individuals with health conditions who may have compromised immune systems.

Overview on Treatment Cost, etc.

Most countries, thanks to government-directed health systems, will provide free testing and treatment, but in the U.S., when appropriate tests are available, it is largely dependent on whether each private insurer (and self-insured employers) will cover COVID-19 testing and treatment. However, the Families First Coronavirus Response Act that was recently passed by Congress mandates that Medicare, Medicaid, other government plans, and most private plans cover the entire COVID-19 testing.  It must be noted that ‘surprise’ billing issues could develop under some scenarios.  There are no curative treatments for the COVID-19 virus itself, so the treatment mentioned in this blog addresses the complications from COVID-19-related illnesses.

According to the Peterson-Kaiser Family Foundation Health System Tracker, the potential costs of COVID-19 treatment for Americans covered by employer health plans will vary greatly by location and insurance plans – in addition to complications and comorbidities. The average hospital stay for admissions due to pneumonia, a relatively similar comparison to treating COVID-19, with or without complications or comorbidities is 3.2 days – with a median total cost of treatment being about $13,000. Patients with respiratory conditions who require a ventilator (requiring less than 96 hours) will average 5.8 days – with a median cost of over $34,223. Finally, patients on ventilators for more than 96 hours will average 22.6 days – with a total median cost of over $88,000.

It is important to note that the actual number of patients and the medical efforts required will ultimately determine the true medical costs, both in Iowa and across the country. Medical costs in Iowa tend to dip below national average costs mentioned earlier.

As of April 5, a research center at the University of Washington estimated that 420 Iowans will die of COVID-19 by August 4. This figure is based on a moving target of assumptions, as it will be greatly dependent on a number of variables such as stay-at-home adherence by Iowans practicing social distancing, number of Iowans affected by the virus, healthcare workforce capacity and availability of medical supplies, adequate number of ventilators, etc. Just three days earlier (April 2), this Iowa estimate was 1,488 fatalities. Facts and assumptions are clearly very fluid at this time. The number of Iowa residents testing positive in the upcoming weeks is expected to peak in late April or early May. The Iowa Department of Public Health provides the latest update on the COVID-19 cases, including the number of Iowans currently hospitalized, discharged and recovering, never hospitalized and deceased.

The majority of people with COVID-19 can be managed at home, but as the cases in China have demonstrated, about 15 percent required hospitalization and another five percent ended up in critical care.

Postponed Medical Visits and Elective Surgeries

Hoping to free up more hospital beds and staff to deal with the COVID-19 surge of patients, many Iowa and U.S. hospitals have postponed elective surgeries and procedures. It is important to note that these ‘elective’ procedures cover many different areas, and in some cases, are still considered urgent, such as cancer, organ transplants and heart conditions, while other procedures, like joint replacements, are not considered to be a medical ‘priority.’ Elective surgery is any surgery that is scheduled.

Certain types of elective surgeries may be postponed for a long time – such as hip and knee replacements – but sometime later this year, or in 2021, there will be a pent-up demand for those types of surgeries. In fact, some procedures could develop into more serious medical conditions, including compromised mental well-being of having prolonged pain and discomfort.

Insurance Companies – Wellmark Blue Cross and Blue Shield of Iowa

On March 20, Wellmark Blue Cross and Blue Shield of Iowa, the state’s largest private insurance company, indicated that it is offering virtual healthcare visits for all appropriate medical and behavioral health visits at no cost to members until June 16. Additionally, Wellmark is covering diagnostic testing for COVID-19 at no cost-share to members. Early refills of prescription drugs are also permitted.

Wellmark then announced on April 1 they will retroactively waive members’ cost-share related to the treatment of COVID-19 – including copays, coinsurance and deductibles – when members seek care from an in-network provider, effective February 4 through at least June 16. By eliminating cost barriers to their fully-insured business and Medicare Supplement members, the desire is to ensure members seek the necessary testing and care regarding COVID-19. Self-funded employers that are administered through Wellmark will decide separately whether to replicate Wellmark’s policy or implement something different.

What Will COVID-19 Mean to Future Private Premium Costs?

How the COVID-19 medical costs will impact private Iowa medical insurance premiums is unknown at this time. Insurance companies, such as Wellmark, establish a ‘reserve’ for claims that are incurred but not yet paid. Additionally, certain statutory requirements for reserves are set aside to help cover unique medical situations that we are currently experiencing. If the COVID-19 claims erode the reserves, insurers may actually have a legal obligation to increase rates to build up those reserves for the next ‘emergency’ sometime later. This is a sound actuarial practice.

Insurers may need to price their 2021 premium rates upward to anticipate a surge in elective surgeries because people have delayed less urgent medical services. On the other hand, the decrease of elective procedures this year may help insurers financially weather the COVID-19 medical costs; their reserves may hopefully be stronger than expected when heading into 2021. A new report from Covered California, the Affordable Care Act marketplace in that state, projects that commercial carriers and employers could face between a $34 billion to $251 billion bill for COVID-19 testing and treatment in 2020, requiring insurers to increase premiums between four percent to 40 percent. Whether the federal government would help mitigate premium growth due to this pandemic is too soon to speculate.

All of this will largely depend on controlling the pandemic as soon as possible. If insurers have to dig deep into their capital reserves, then all bets are off on just how much higher health insurance premiums will need to be in 2021.

As one insurance professional mentioned to me last week, “Reserve adequacy is a function of rate adequacy.” In other words, rates will need to be adjusted upward to ensure the claims and reserves are adequate for future emergencies.

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Filed Under: David P. Lind, Lindex Tagged With: , , , , , ,