/ en Fri, 25 Apr 2025 12:24:44 -0500 Tue, 11 Mar 25 12:52:15 -0500 /testimony/2025-03-11-aha-statement-house-ways-and-means-subcommittee-health-hearing-march-11-2025 <div class="container"><div class="row"><div class="col-md-8"><h2>Statement<br>of the<br>şÚÁĎŐýÄÜÁż Association<br>for the<br>Committee on Ways and Means<br>Subcommittee on Health<br>of the<br>U.S. House of Representatives<br>“After the Hospital: Ensuring Access to Quality Post-Acute Care”<br>March 11, 2025</h2><p>On behalf of our nearly 5,000 member hospitals and health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and our 2,425 post-acute care members, the şÚÁĎŐýÄÜÁż Association (AHA) appreciates the opportunity to submit this statement for the record to the Ways and Means Subcommittee on Health on the value of post-acute care and how Congress can better support patients’ access to these critical services.</p><h2>General Policy & Regulatory Challenges</h2><p>Post-acute care is provided to patients who have been discharged from an acute-care hospital but still require services such as close medical supervision, nursing care, therapies and other support. Long-term care hospitals (LTCHs) act as a pressure relief valve for high-acuity patients needing extended hospital stays, thereby easing the burden on intensive care units (ICUs). Inpatient rehabilitation facilities (IRFs) assist patients recovering from life-changing illnesses like brain injuries, spinal cord injuries and amputations. Skilled nursing facilities (SNFs) offer rehabilitation therapy services aimed at strengthening patients and making them more independent before they return home. Home health agencies (HHs) enable seniors to remain independent by providing medical or non-medical care in their homes. Each of these facilities plays a crucial role across the continuum of care.</p><p>While each specific post-acute sector faces unique challenges, there are several policy and regulatory issues that are universal.</p><h3>Medicare Advantage</h3><p>Medicare Advantage (MA) plans are an increasingly popular choice for older Americans, and measures must be taken to ensure that patients who require post-acute care services are able to access them in a timely manner. Perhaps the biggest challenge facing post-acute care providers and their patients is the ongoing restrictions that MA plans place on access to care. The issue has been well documented by providers as well as by Department of Health and Human Services Office of Inspector General and congressional investigations.<a href="#fn1"><sup>1</sup></a><sup>,</sup><a href="#fn2"><sup>2</sup></a> The prior authorization process used by MA plans places significant administrative burden on both acute-care hospitals and post-acute care providers. Perhaps more importantly, it is directly harmful to Medicare beneficiaries — at best delaying their care and at worst outright denying medically necessary treatment.</p><p>MA plans’ practices have directly contributed to the growing discharge delay problems plaguing acute-care hospitals. While all beneficiaries have faced these delays, the increase in length of stay for MA beneficiaries seeking post-acute care has increased twice as much compared to Traditional Medicare beneficiaries. Specifically, the average length of stay (ALOS) prior to discharge to post-acute care settings has grown by 11.3% for MA patients between 2019 and 2024. However, for patients in Traditional Medicare, the ALOS has grown by only 5.2%, according to industry benchmark data from Strata Decision Technology, LLC.</p><p>Despite steps taken by the Centers for Medicare & Medicaid Services (CMS) in recent years, providers have seen little to no meaningful change in MA plan behavior and no increased access for beneficiaries. Additionally, post-acute care providers still face challenges with MA plans listing them within their networks. CMS should conduct regular audits to ensure that MA plans include robust post-acute care options with sufficient bed spaces and resources to provide the in-network care that patients need. As MA enrollment continues to grow, it is imperative that Congress continue to rein in these harmful practices to ensure that beneficiaries are not denied the care to which they are entitled.</p><h3>Ongoing Workforce Challenges</h3><p>The U.S. health care system is facing unprecedented workforce shortages, with the Bureau of Labor Statics estimating there will be 193,100 openings for nurses in each of the next 10 years.<a href="#fn3"><sup>3</sup></a> For physicians, there could be a shortage of between 37,800 and 124,000 physicians by 2034 for both primary and specialty care.<a href="#fn4"><sup>4</sup></a> Since mid-2020, post-acute care providers have seen a significant number of patient care technicians, registered nurses, and respiratory therapists, among other vital professionals, shifting employment to other organizations. Some post-acute care providers in rural areas have experienced significant challenges in filling open positions, sometimes going months without receiving an application for open registered nurses, licensed practical nurses, certified nursing assistants or key leadership roles. Staffing challenges jeopardize the ability of seniors to access the care they need and deserve.</p><p>To ensure residents and families have access to high-quality care close to home, meaningful, long-term solutions and investments in workforce development must replace stop-gap measures, reimbursement cuts and punitive regulations. The AHA encourages Congress to pass the Conrad State 30 and Physician Access Reauthorization Act (S.709/H.R.1585) and the Healthcare Workforce Resilience Act, as well as support visa recapture initiatives and continue support for the Health Resources and Services Administration’s (HRSA) health professions and nursing workforce development programs.</p><h2>Sector Specific Comments</h2><h3>Long-Term Care Hospitals</h3><p>LTCHs play a unique role for Medicare and other beneficiaries by caring for the most severely ill patients who require extended hospitalization. LTCHs offer an intensive, hospital-level of care that may not be available in other post-acute care settings. LTCH patients are typically very medically complex, with multiple organ failures, and stay in LTCHs on average for at least 25 days. Many LTCH patients depend on ventilators due to respiratory failure or similar ailments, which require highly specialized care and extended stays. In addition, LTCHs are critical partners for acute-care hospitals, alleviating capacity for overburdened ICUs and other parts of the care continuum that would otherwise be further strained without access to LTCHs for these patients.</p><p>In 2016, Congress put in place a dual-rate payment system under the LTCH prospective payment system (PPS) for Traditional Medicare beneficiaries.<a href="#fn5"><sup>5</sup></a> This fundamental change in the payment system and other coinciding market factors dramatically reshaped the landscape of both LTCHs and the beneficiaries they serve. Since implementation of the dual-rate payment system, the volume of standard LTCH cases has fallen by approximately 70% from its peak under the legacy payment system and the number of LTCH providers also has decreased by 20%. At the same time, the average acuity of LTCH patients has risen by 20% or more in that same period, and these patients are increasingly consolidated into a limited number of Diagnosis-Related Groups (DRGs).<a href="#fn6"><sup>6</sup></a> In addition, approximately one-third of all Medicare LTCH discharges nationally are paid the inpatient PPS-equivalent rate. However, these reimbursements fall well short of the cost of care. AHA’s analysis shows that as of fiscal year 2020 reimbursement for these cases totaled only 46% of the cost of care.<a href="#fn7"><sup>7</sup></a> Finally, the growth of MA has further shrunk the patient population for LTCHs as MA plans routinely inappropriately deny access to LTCHs.</p><p>The smaller, sicker patient population and dwindling reimbursement has created many challenges for LTCHs, as evidenced by the closure of so many of these facilities. The remaining patient pool is notably more acute and costly to treat, resulting in cases increasingly qualifying for high-cost outlier (HCO) payments to compensate for lack of precision in the DRGs as so many cases are consolidated into a limited number of DRGs. In 2016, the fixed-loss amount (FLA) for HCO cases, which is the amount of financial loss an LTCH must incur before qualifying for an HCO payment, was $16,423. Since that time, the FLA has risen by more than 300% to $77,048. This unsustainable figure puts LTCHs in the untenable position of having to lose tens of thousands of dollars in order to care for some of the sickest patients. Unfortunately, CMS has been unable to deviate from its current methodology to provide relief from this policy due to a congressional mandate to cap total outlier payments at 8% of total payments.<a href="#fn8"><sup>8</sup></a></p><p>The AHA appreciates this Subcommittee’s awareness of the need to provide relief to the LTCH sector and supports efforts to provide additional flexibility and funding for HCO cases, and additional flexibility to provide care for different types of patients through the standard payment system.</p><h3>Inpatient Rehabilitation Facilities</h3><p>IRF patients are typically admitted directly from an acute-care hospital following a serious accident or illness such as stroke, brain injury, amputation or others that have resulted in serious functional deficits and medical complications. IRFs provide hospital-level care, which means they are closely supervised by a physician who also oversees patients’ overall rehabilitation. The intensive course of rehabilitation provided in IRFs must include a minimum of 15 hours per week of intensive therapy services involving multiple therapy disciplines, as well as around-the-clock specialized nursing care. This level of care is critical for debilitated patients who are stable enough to be discharged from the acute-care hospital to begin intensive rehabilitation but are at risk for medical complications without continued close medical management.</p><p>The AHA continues to hear from IRFs regarding their concerns with CMS’ IRF Review Choice Demonstration (RCD). CMS initially created the IRF RCD to “assist in developing improved procedures for the identification, investigation, and prosecution of potential Medicare fraud.” However, the agency never provided credible evidence to support its belief that there may be high rates of fraud in the IRF field — it only cited its improper payment rate for IRFs, which, as it knows, is not the same as fraud. Since being operationalized by the Biden administration in 2023, CMS has not subsequently provided any evidence that the IRF RCD has revealed or assisted in uncovering any fraud. Specifically, the demonstration currently subjects 100% of IRF claims to review in both Alabama and Pennsylvania. Yet, according to CMS’ <a href="https://www.cms.gov/files/document/irf-rcd-stats-fy-2024.pdf" target="_blank" title="CMS: Review Choice Demonstration for Inpatient Rehabilitation Facility Services (IRF RCD) Quarterly Updates. Fiscal Year 2024 (Oct 2023 – Sept 2024).">most recent data</a> collected during fiscal year 2024, approximately 90% of all claims reviewed have been approved. Of those, more than 95% were approved on the initial submission. Despite this high affirmation rate and lack of evidence of any fraud, CMS says it still plans to continue its expansion of the demonstration to more than half of all states and territories, subjecting hundreds of thousands of IRF claims annually to the burdensome manual medical review process. It has become clear that this demonstration is burdensome, diverts valuable clinical resources, and is not achieving its stated objective of uncovering or preventing fraud in the Medicare program.</p><p>Therefore, the continued need for the IRF RCD remains highly dubious, and the AHA continues to encourage CMS and Congress to end this program.</p><h3>Skilled Nursing Facilities</h3><p>SNFs play another critical role for many hospitalized patients who need continued care after discharge. However, hospitals have faced increasing difficulty discharging patients to post-acute care settings, including SNFs. This challenge has largely been due to staffing shortages and the associated reduced capacity of SNFs and other providers. These shortfalls then place additional burden back on hospitals, including the need for hospitals to board patients until a discharge location can be found. Therefore, it is vital for the entire continuum of care, including for acute-care hospitals, that SNFs are properly resourced.</p><p>The AHA and its members are committed to safe staffing to ensure high-quality, patient-centered care in all health care settings, including long-term care (LTC) facilities. Yet, the process of safely staffing any health care facility is about much more than achieving an arbitrary number set by regulation. It requires clinical judgment and flexibility to account for patient needs, facility characteristics, and the expertise and experience of the care team. The Biden administration’s one-size-fits-all minimum staffing rule for LTC facilities creates more problems than it solves and could jeopardize access to all types of care across the continuum, especially in rural and underserved communities that may not have the workforce levels to support these requirements.</p><p>The AHA supports the Protecting America’s Seniors Access to Care Act (H.R. 1683) to prohibit the Department of Health and Human Services from implementing the provisions of the minimum staffing rule. We have recommended to CMS specific alternative strategies that take more patient- and workforce-centered approaches to ensuring LTC facilities have a strong foundation of policies and processes to continually assess, reassess and adjust their staffing levels. These strategies constitute starting points for further standards development, which we would encourage CMS to engage in with the assistance of patients and the entire health care continuum. Not only would these proposed alternatives support more timely and effective action by LTC facilities to address staffing challenges, but they also would be more consistent with modern clinical practice. Thus, repealing the Biden-era mandate would both protect patient access to care and allow for the development of more effective and clinically appropriate strategies to improve LTC patient outcomes.</p><h3>Home Health Agencies</h3><p>Approximately one in five hospitalized Medicare beneficiaries are discharged to HH.<a href="#fn9"><sup>9</sup></a> These services alleviate pressure on hospitals, other post-acute care sites and caregivers, who would otherwise be responsible for these patients. HH agencies also can prevent rehospitalization by safely providing needed interventions at home thus avoiding potential complications and accidents.</p><p>Over the last few years, the AHA has seen a strain on HH operations — along with other post-acute care providers — due to financial challenges, creating ripple effects throughout the continuum of care. Hospitals have seen the length of stay for patients being discharged to HH increase as they face increasing difficulty finding placements for these patients.<a href="#fn10"><sup>10</sup></a> This has been due in large part to the reductions in reimbursement to HH providers put in place by CMS since its implementation of the new Medicare fee-for-service payment system in 2020. CMS determined it must permanently cut HH payments from between 4% to 8% annually in order to meet statutory budget neutrality requirements. In addition, CMS has indicated that it intends to recoup billions more in temporary reductions in the coming years. These payment reductions, paired with staffing shortages, and other administrative burdens and costs will continue to have serious implications for access to services for Medicare beneficiaries. The AHA is thankful for the Committee’s ongoing support of home health agencies.</p><h2>Conclusion</h2><p>Thank you for your leadership on these important issues and for the opportunity to provide comments. We look forward to continuing to work with you to address these important topics on behalf of our patients and communities.</p><hr><ol><li id="fn1">HHS, Office of Inspector General (OIG); Some Medicare Advantage Organization Denials of Prior Authorization Requests Raise Concerns About Beneficiary Access to Medically Necessary Care (April 2022) (<a href="https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf" target="_blank">https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf</a>).</li><li id="fn2"><a href="https://www.hsgac.senate.gov/wp-content/uploads/2024.10.17-PSI-Majority-Staff-Report-on-Medicare-Advantage.pdf" target="_blank">https://www.hsgac.senate.gov/wp-content/uploads/2024.10.17-PSI-Majority-Staff-Report-on-Medicare-Advantage.pdf</a>.</li><li id="fn3">3<a href="https://www.bls.gov/ooh/healthcare/registered-nurses.htm#tab-6" target="_blank">https://www.bls.gov/ooh/healthcare/registered-nurses.htm#tab-6</a>.</li><li id="fn4">4<a href="https://www.aamc.org/news/press-releases/aamc-report-reinforces-mounting-physician-shortage" target="_blank">https://www.aamc.org/news/press-releases/aamc-report-reinforces-mounting-physician-shortage</a>.</li><li id="fn5">Bipartisan Budget Act Of 2013 (P.L. 113–67).</li><li id="fn6"><a href="/white-papers/2023-12-29-white-paper-medicares-ltch-outlier-policy-needs-reforms-protect-extremely-ill-beneficiaries" target="_blank">/white-papers/2023-12-29-white-paper-medicares-ltch-outlier-policy-needs-reforms-protect-extremely-ill-beneficiaries</a>.</li><li id="fn7"><a href="/system/files/media/file/2019/06/aha-cms-long-term-care-proposed-rule-fy2020-6-21-2019_0.pdf" target="_blank">/system/files/media/file/2019/06/aha-cms-long-term-care-proposed-rule-fy2020-6-21-2019_0.pdf</a>.</li><li id="fn8">Section 15009(b) of the 21ST Century Cures Act added section 1886(m)(7) to the Act.</li><li id="fn9">MedPAC; July 2024 Data Book; Section 8, Pg. 107 (<a href="https://www.medpac.gov/wp-content/uploads/2024/07/July2024_MedPAC_DataBook_Sec8_SEC.pdf" target="_blank">https://www.medpac.gov/wp-content/uploads/2024/07/July2024_MedPAC_DataBook_Sec8_SEC.pdf</a>).</li><li id="fn10"><a href="/lettercomment/2024-08-26-aha-comments-calendar-year-2025-home-health-prospective-payment-system-proposed-rule" target="_blank">/lettercomment/2024-08-26-aha-comments-calendar-year-2025-home-health-prospective-payment-system-proposed-rule</a>.</li></ol></div><div class="col-md-4"><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2025/03/AHA-Statement-to-House-Ways-and-Means-Subcommittee-on-Health-for-Hearing-March-11-2025.pdf" target="_blank" title="Click here to download the AHA Statement to House Ways and Means Subcommittee on Health for Hearing March 11, 2025 PDF.">Download the Testimony PDF</a></div><a href="/system/files/media/file/2025/03/AHA-Statement-to-House-Ways-and-Means-Subcommittee-on-Health-for-Hearing-March-11-2025.pdf"><img src="/sites/default/files/inline-images/Page-1-AHA-Statement-to-House-Ways-and-Means-Subcommittee-on-Health-for-Hearing-March-11-2025.png" data-entity-uuid="ef5df51a-efdf-417b-bd24-197ee16b5607" data-entity-type="file" alt="AHA Statement to House Ways and Means Subcommittee on Health for Hearing March 11, 2025 page 1." width="695" height="900"></a></div></div></div> Tue, 11 Mar 2025 12:52:15 -0500 Testimony /testimony/2024-09-18-aha-statement-legislative-proposals-be-considered-energy-and-commerce-committee-sept-18 <div class="container"><div class="row"><div class="col-md-8"><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated<br>physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) appreciates the opportunity to provide comments on legislative proposals that are to be considered before the Energy and Commerce Committee on Sept. 18.</p><p>We would like to provide feedback on sections of H.R. 7623 as amended (H7623-FC-AINS_01.XML) and H.J. Res. 139.</p><h2>H.R. 7623, TELEHEALTH MODERNIZATION ACT</h2><p><strong>The AHA supports</strong> two-year extensions for key telehealth flexibilities before they expire on Dec. 31, 2024, to maintain patients’ access to quality virtual care. We appreciate the committee’s commitment to ensuring that essential telehealth flexibilities are extended so that patients continue to receive access to high-quality care. The expansion of telehealth services has transformed care delivery, expanded access for millions of Americans and increased convenience in caring for patients, especially those with transportation or mobility limitations.</p><p>In addition, the AHA supports Section 104 which would require dissemination of best practices to support individuals with limited English proficiency in accessing telehealth services, and Section 105, which would enable patients to receive in-home telehealth care for cardiac rehabilitation services administered from hospitals or hospital outpatient departments.</p><p>AHA supports Section 102 to extend the hospital-at-home waiver for five years, through the end of 2029. Over the past few years, hospitals and health systems have expressed the need for long-term stability within the H@H program. Standing up a H@H program requires logistical and technical work, with an investment of time, staff and money. In addition to being approved for the federal waiver, some providers must navigate additional regulatory requirements at the state level. For some, this whole process could take a year or more to complete before the first patient can be seen at home.</p><p><strong>However, the AHA opposes Section 404</strong> which would require a separate identification number and an attestation for each off-campus outpatient department of a provider.</p><p><strong>The AHA urges the committee to strike this section</strong> which would require that each off-campus hospital outpatient department (HOPD) be assigned a separate unique health identifier. Hospitals and other providers bill according to federal regulations, which require them to bill all payers — Medicare, Medicaid and private payers — using codes that indicate the location of where a service is provided. As a result, this provision would impose an unnecessary and onerous administrative burden on providers and needlessly increase Medicare program administrative costs.</p><p>This section also would require that as a condition of payment, hospitals submit an attestation of compliance with the Medicare provider-based regulations for each of their off-campus HOPDs within two years of enactment. Given hospitals’ experience with review and approval of similar attestations in the past, we are concerned that this requirement would be extremely burdensome for hospitals and Medicare contractors and therefore urge the committee to reject this provision.</p><p><strong>H.J.Res.139, PROVIDING FOR</strong> <strong>CONGRESSIONAL DISAPPROVAL UNDER CHAPTER 8 OF TITLE 5, UNITED STATES CODE, OF THE RULE SUBMITTED BY THE CENTERS FOR MEDICARE & MEDICAID SERVICES RELATING TO "MEDICARE AND MEDICAID PROGRAMS: MINIMUM STAFFING STANDARDS FOR LONG-TERM CARE FACILITIES AND MEDICAID INSTITUTIONAL PAYMENT TRANSPARENCY REPORTING”</strong></p><p><strong>The AHA supports</strong> H.J.Res.139 for Congress to disapprove of this rule and prohibit the Secretary of Health and Human Services from implementing or enforcing this rule. The AHA and its members are committed to safe staffing to ensure high-quality, equitable and patient-centered care in all health care settings, including long-term care (LTC) facilities. Yet, the process of safely staffing any health care facility is about much more than achieving an arbitrary number set by regulation. The Centers for Medicare & Medicaid Services’ (CMS) one-size-fits-all minimum staffing rule for LTC facilities creates more problems than it solves and could jeopardize access to all types of care across the continuum, especially in rural and underserved communities that may not have the workforce levels to support these requirements.</p><p>We believe this final rule could exacerbate the already serious shortages of nurses and skilled health care workers across the care continuum. The agency estimates that 79% of LTC facilities would have to increase staffing to meet the proposed standards, including the new standard requiring 24/7 RN staffing. Considering the massive structural shortages described by recent studies, it is unclear from where this supply of nurses will come, and it is inconceivable that LTC facilities will be able to meet these standards without detrimental effects on workforce availability throughout the care continuum. Strengthening the health care workforce requires investment and innovation, not inflexible mandates.</p><h2>CONCLUSION</h2><p>Thank you for your consideration of the AHA’s comments on these legislative proposals. We look forward to continuing to work with you to address these important topics on behalf of our patients and communities.</p></div><div class="col-md-4"><a href="/system/files/media/file/2024/09/aha-statement-on-legislative-proposals-to-be-considered-before-energy-and-commerce-committee-sept-18-testimony-9-18-2024.pdf"><img src="/sites/default/files/inline-images/cover-aha-statement-on-legislative-proposals-to-be-considered-before-energy-and-commerce-committee-sept-18-testimony-9-18-2024.png" data-entity-uuid data-entity-type="file" width="654" height="849" alt=" AHA Statement on Legislative Proposals to be Considered Before Energy and Commerce Committee On Sept. 18 page 1."></a></div></div></div> Wed, 18 Sep 2024 00:06:14 -0500 Testimony /testimony/2024-09-11-aha-statement-house-committee-education-and-workforce-markup-hearing-sept-11-2024 <div class="container"><div class="row"><div class="col-md-8"><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) appreciates the opportunity to provide comments on legislation to be considered during the committee’s executive session on Sept. 11, 2024. The AHA is providing feedback on the Healthy Competition for Better Care Act (H.R. 3120) and the Transparent Telehealth Bills Act of 2024 (H.R. 9457).</p><h2>Healthy Competition for Better Care Act (H.R. 3120)</h2><p>The AHA opposes the Healthy Competition for Better Care Act (H.R. 3120), which would lead to fewer choices for patients and further limit access to care, particularly for patients in urban, rural and other vulnerable communities.</p><p>This bill includes harmful contracting provisions that would prevent doctors and hospitals from negotiating reasonable agreements with commercial health insurance plans. These contracting restrictions — known as tiering or steering — would allow insurers to make it more difficult for patients to choose their own doctors and hospitals by steering them to the providers the insurers own or favor. If passed, this bill would limit patient’s choice and ability to seek care with their preferred providers and hospitals in their communities.</p><p>This bill also would allow large commercial insurers to make financially driven decisions about which hospitals in a network are under contract, enabling them to avoid hospitals serving vulnerable communities or those that serve sicker patients with serious or chronic conditions.</p><p>The AHA is concerned that this bill could cause patients in underserved communities, including rural areas with high poverty rates, to lose access to care and health care coverage as insurers could decide the providers in a hospital network to avoid contracting with those in areas the insurer finds less financially desirable. Because providing health care in rural areas is typically more costly than in other areas, an insurer could force rural patients to go elsewhere for services. Forcing patients to travel long distances for care will lead to delays or missed medical attention.</p><p>Additionally, this bill may increase rural hospital closures. If insurers are allowed to prevent rural patients from receiving services in their communities, local providers will be unable to cover high fixed operating costs. The resulting financial strain will lead to less access to care and fewer coverage options as insurance plans would not cover the local doctors and hospitals in those rural and high-poverty areas.</p><p>Congress should not force providers to agree to unfair tiering and/or steering restrictions, which would allow commercial insurers to further undermine providers’ efforts to coordinate high-quality care. Commercial insurers cannot be allowed to profit from contracts premised on the provider’s capacity to serve its patients while simultaneously undermining them by encouraging patients to go elsewhere for care. These restrictions are unnecessary because studies show that the vast majority of health insurance marketplaces are highly concentrated. With commercial insurers already having such significant market power, they do not need Congress to grant them additional advantages through these contracting restrictions that will ultimately harm many patients’ access to quality care.</p><h2>Transparent Telehealth Bills Act of 2024 (H.R. 9457)</h2><p>The AHA opposes the Transparent Telehealth Bills Act of 2024 (H.R. 9457), which would cut hospital reimbursements since payment (including facility fees and any additional services) would be capped for facility-based providers at non-facility rates. Facility fees are for the direct and indirect costs that allow a hospital to continue to provide services to patients and serve the needs of their community. They support the high acuity and 24/7 standby capacity that only hospitals provide and for which payers do not cover the full cost.</p><p>The cost of care delivered in hospitals and health systems recognizes the unique benefits they provide to their communities, which are not provided by other sites of care. This includes investments made to maintain standby capacity for natural and man-made disasters, public health emergencies and unexpected traumatic events, and delivering 24/7 emergency care to all who come to the hospital, regardless of ability to pay or insurance status. In addition, hospital facilities also must comply with a more comprehensive scope of licensing, accreditation and other regulatory requirements compared to other sites of care. These costs can amount to over $200 per patient, resulting in hospitals losing money when providing certain services.</p><p>This is especially true for telehealth services. The expansion of telehealth over the past few years has transformed care delivery, improved access for millions of Americans and increased patient convenience. Given the current health care challenges across sites of care, including major clinician shortages, telehealth holds tremendous potential to leverage geographically dispersed provider capacity to support patient demand. The telehealth value propositions of improving access for geographically dispersed patients and maximizing provider capacity apply equally to facility settings (including hospitals and hospital outpatient departments) and non-facility professional settings. We are deeply concerned that reducing reimbursement for facility-based providers by establishing payment thresholds not to exceed the non-facility rates, will further limit the administration of virtual services for patients and communities.</p><p>The originating site facility fee supports reimbursement for staff time (for nurses or other clinical staff to set up the video visit/equipment and proctor the visit), facility space and technology. For example, a patient physically located at a rural health clinic may require a specialty consult from a remote hospital-based provider, in which case the rural health clinic would be able to bill for the originating facility site facility fee to help cover the costs of the technology used in the visit (like secure software), the overhead for facility space (and therefore not available for other in-person appointments) and staff time to support the visit.</p><p>Imposing these cuts would endanger the critical roles hospitals and health systems play in their communities, including providing access to care for patients.</p><h2>Conclusion</h2><p>Thank you for your consideration of the AHA’s comments on these legislative proposals. We look forward to working with you on these important issues.</p></div><div class="col-md-4"><p><a href="/system/files/media/file/2024/09/AHA-Statement-to-House-Committee-on-Education-and-the-Workforce-for-Markup-Hearing-Sept-11-2024.pdf" target="_blank" title="Click here to download the AHA Statement to House Committee on Education and the Workforce for Markup Hearing Sept. 11, 2024, PDF."><img src="/sites/default/files/inline-images/Page-1-AHA-Statement-to-House-Committee-on-Education-and-the-Workforce-for-Markup-Hearing-Sept-11-2024.png" data-entity-uuid="19fe0da6-b875-4a00-a74b-52318a9fd505" data-entity-type="file" alt="AHA Statement to House Committee on Education and the Workforce for Markup Hearing Sept. 11, 2024, page 1." width="692" height="900"></a></p></div></div></div> Wed, 11 Sep 2024 06:00:00 -0500 Testimony /testimony/2024-07-11-aha-senate-statement-record-health-care-transparency-lowering-costs-and-empowering-patients <p class="text-align-center"><strong>Statement</strong><br><strong>of the</strong><br><strong>şÚÁĎŐýÄÜÁż Association</strong><br><strong>for the</strong><br><strong>Special Committee on Aging</strong><br><strong>of the</strong><br><strong>United States Senate</strong><br><strong>“Health Care Transparency: Lowering Costs and Empowering Patients”</strong><br><br><strong>July 11, 2024</strong></p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) writes to share the hospital field’s comments on health care costs and transparency.</p><h2>OVERVIEW OF NATIONAL HEALTH SPENDING</h2><p>America’s hospitals and health systems — physicians, nurses and other caregivers — understand and share concerns regarding the high cost of health care and are working hard to make care more affordable by transforming the way health care is delivered in our communities. Real change will require an effort by everyone involved, including providers, the government, employers and individuals, device makers, drug manufacturers, insurers and other stakeholders.</p><p>The AHA’s most recent “<a href="/system/files/media/file/2024/05/Americas-Hospitals-and-Health-Systems-Continue-to-Face-Escalating-Operational-Costs-and-Economic-Pressures.pdf" target="_blank" title="Cost of Caring Report">Cost of Caring</a>” report provides greater details on the challenges hospitals face with respect to treating patients with higher acuities while dealing with financial instability. The issues include workforce shortages and increasing supply chain costs, coupled with inadequate reimbursement from government payers and increased administrative burden related to commercial insurance efforts to reduce compensation. Taken together, these factors create an environment of financial uncertainty in which many hospitals and health systems are operating with little to no margin.</p><p>For this statement, we highlight two of the cost drivers incurred by hospitals and health systems: commercial insurer operating methods and prescription drug costs.</p><h3>Commercial Insurer Practices</h3><p>To truly reduce health care costs, we urge Congress to address practices by certain commercial health insurers. For example, additional oversight is needed to ensure that Medicare Advantage (MA) plans can no longer engage in tactics that restrict and delay access to care while adding burden and cost to the health care system.</p><p>While MA plans were designed to help increase efficiency in the Medicare program, data from the Medicare Payment Advisory Commission (MedPAC) found that MA plans will be responsible for $88 billion in excess federal spending this year, due in part to inappropriate upcoding practices, whereby plans report enrollees as having more health conditions and being sicker than they are to receive higher reimbursements. At the same time, health insurance premiums continue to grow — in fact, annual insurance premiums increased nearly twice as much as hospital prices over a 10-year period.<sup>1</sup></p><p>Additionally, inappropriate denials for prior authorization and coverage of medically necessary services remain a pervasive problem among certain MA plans. A 2022 report from the Department of Health and Human Services (HHS) Office of Inspector General found that MA plans are denying at a high rate medically necessary care that met Medicare criteria.<sup>2</sup> The report highlights that 13% of prior authorization denials and 18% of payment denials met Medicare coverage rules and therefore should have been approved. In a program this size — covering more than half of all Medicare beneficiaries — improper denials at this rate are unacceptable. However, because the government pays MA plans a risk-adjusted per-beneficiary capitation rate, there is a perverse incentive to deny services to patients or payments to providers to boost profits.</p><p>These practices delay access to care for seniors and add financial burden and strain on the health care system through inappropriate payment denials and increased staffing and technology costs to comply with plan requirements. They also are a major burden to the health care workforce and contribute to provider burnout. To address these issues, the AHA supports regulatory and legislative solutions that streamline and improve prior authorization processes, including the Improving Seniors’ Timely Access to Care Act (S. 4532), which would codify many of the reforms in the Interoperability and Prior Authorization Final Rule.</p><p>Though issues with denials are often felt most acutely with MA and Medicaid managed care plans, these practices also are followed by other commercial payers, where claims denials increased by 20.2% in 2023. Moreover, the time taken by commercial payers to process and pay hospital claims from the date of submission increased by 19.7% in 2023, according to data from the Vitality Index. For hospitals and health systems, these practices, which require hospitals to divert dollars away from patient care to instead focus on seeking payment from commercial insurers, result in billions of dollars in lost revenue each year.<sup>3</sup> Without further intervention, these trends are expected to continue and worsen. National expenditures on the administrative costs of private health insurance spending alone are projected to account for 7% of total health care spending between 2022 and 2031 and are projected to grow faster than expenditures for hospital care.<sup>4</sup></p><h3>Prescription Drug Prices</h3><p>Congress also should address the high costs of prescription medications, given the regular increases in costs, as this impacts expenses for all providers, including hospitals. For instance, a report from earlier this year noted pharmaceutical companies raised list prices on 775 brand name drugs during the first half of January 2024, with a median increase of 4.5%, though the prices of some drugs rose by 10% or higher.<sup>5</sup> These increases were higher than the rate of inflation, which was 3.4% in December. A report by the HHS Assistant Secretary for Planning & Evaluation (ASPE) found that between 2022 and 2023 drug companies increased drug prices for nearly 2,000 drugs faster than the rate of general inflation, with an average price hike of 15.2%.<sup>6</sup></p><p>Moreover, recent drug shortages also have fueled further expense growth. An ASPE report found up to a 16.6% increase in the prices of drugs in shortage; in many cases, the increase in the price of substitute drugs were at least three times higher than the price increase of the drug in shortage<sup>.7</sup> The costs incurred as a result of drug shortages are compounded by staff overtime needed to find, procure and administer alternative drugs, to manage the added challenges of multiple medication dispensing automation systems and changing electronic health records and to undergo training to ensure medication safety using alternative therapies<sup>.8</sup></p><h2>MEDICAL DEBT</h2><p>Hospitals and health systems are very concerned about patients’ medical debt, which is a consequence of patients not paying some or all their health care bills. While health insurance is intended to be the primary mechanism to protect patients from unexpected and unaffordable health care costs, for too many that coverage is either unavailable or falling short.</p><p>Trends in health insurance coverage that are driving an increase in medical debt include inadequate enrollment in comprehensive health care coverage, growth in high-deductible and skinny health plans that intentionally push more costs onto patients and misleading health plan practices that confuse patients’ understanding of their coverage. These gaps in coverage leave individuals financially vulnerable when seeking medical care. The primary causes of medical debt are:</p><ul><li><strong>There are still too many uninsured Americans</strong>. Affordable, comprehensive health care coverage is the most important protection against medical debt. While the U.S. health care system has achieved higher rates of coverage over the past decade, gaps remain.</li><li><strong>High-deductibles subject many Americans to cost-sharing they cannot afford</strong>. High-deductible plans are designed to increase patients’ financial exposure through high cost-sharing in exchange for lower monthly premiums. Yet many individuals enrolled in high-deductible plans find they cannot manage their portion of health plan expenses. A Federal Reserve report found that 37% of adults would not be able to afford a $400 emergency<sup>,9</sup> an amount $1,000 less than the average general annual deductible for single, employer-sponsored coverage.</li><li><strong>Certain health plans provide inadequate benefits and frequently lead to surprise gaps in coverage</strong>. Short-term, limited-duration health plans and health sharing ministries cover fewer benefits and include few to no consumer protections, such as required coverage of pre-existing conditions and limits on out-of-pocket costs. Patients with these types of plans often find themselves responsible for their entire medical bill without any help from their health plan, including for critical services such as emergency medical and oncology care. These denials can lead to an accumulation of significant medical debt.<sup>10</sup></li><li><strong>Complex health plan benefit design and misleading marketing can expose patients to unexpected costs</strong>. Many health plans have complex benefit designs that are not transparent to patients, such as what is covered pre-deductible, the interaction between point-of-service copays, coinsurance and deductibles and poor communication and education about what the plan covers. For example, a recent National Association of Insurance Commissioners report found significant gaps and inconsistencies with the way that insurers share information about pre-deductible, no cost-sharing preventive services with their members, resulting in a “meaningful barrier to effective understanding and use of preventive service benefits.”<sup>11</sup></li></ul><p>Hospitals are the only part of the health care sector that provide services to patients regardless of their ability to pay. They underscore that commitment by offering financial and other assistance, including helping patients qualify for federal and state health care programs, such as Medicaid. In doing so, patients can receive regular preventive care, not just episodic care for serious injuries or illness. In addition, hospitals absorb billions of dollars of losses for patients who are unable to pay their bills, mainly due to inadequate commercial insurance coverage; in 2020, the latest figure available, hospitals provided more than $42 billion in uncompensated care.<sup>12</sup></p><p>This is why hospitals are staunch supporters of ensuring everyone is enrolled in some form of comprehensive coverage. However, we appreciate that closing the remaining coverage gaps may be a longer-term solution and that more immediate steps can be taken. To that end, the AHA has routinely developed patient billing guidelines to help prevent patients from incurring medical debt. The AHA’s Board of Trustees adopted the most recent <a href="/standardsguidelines/2020-10-15-patient-billing-guidelines" target="_blank">set of guidelines</a> in 2020, which reaffirm the hospital field’s commitment to:</p><ul><li>Treating all people equitably, with dignity, respect and compassion.</li><li>Serving the emergency health care needs of all, regardless of a patient’s ability to pay.</li><li>Assisting patients who cannot pay for part or all the care they receive.</li></ul><p>Notably, several of the guidelines directly address medical debt, including encouraging hospitals to forego adverse credit reporting of medical debt. So far, nearly 2,800 hospitals and health systems have affirmed their commitment to the guidelines, and the AHA revisits them regularly for updating.</p><h2>PRICE TRANSPARENCY REQUIREMENTS</h2><p>We appreciate Congress’ ongoing interest in hospital price transparency to provide consumers with the price information they need specific to their course of treatment.</p><p>Hospitals and health systems have invested considerable time and resources to comply with the Hospital Price Transparency Rule, which requires online access to both a machine-readable file and a list of shoppable services. Recent data from Turquoise Health shows that 93.4% of hospitals have met the requirement to post a machine-readable file.</p><p>We are concerned, however, with recent legislative efforts to no longer recognize price estimator tools as a method to meet the shoppable services requirement. This change would both reduce access to a consumer-friendly research tool and unfairly penalize hospitals that have spent significant capital to comply with the regulation. These facilities would instead need to develop and maintain a shoppable services spreadsheet, which may be difficult for consumers to navigate and will not reflect the different policies that their insurer may apply to determine the final price for a service. Price estimator tools offer consumers an estimate of their out-of-pocket costs based on their insurance benefit design, such as cost-sharing requirements and prior utilization, as well as the patient’s annual deductible. This is an important feature of these tools that is not available from a shoppable services spreadsheet. Eliminating the use of price estimator tools as a method to meet the shoppable services requirement of the Hospital Price Transparency Rule would therefore reduce price transparency for patients. We urge Congress to reject this potential change.</p><p>As Congress seeks to make statutory changes to price transparency standards, it is important for legislators to take into consideration the adjustments to the Hospital Price Transparency Rule made by the Centers for Medicare & Medicaid (CMS) on a regular basis. These include changes related to standardization, new data elements, file accessibility, an accuracy and completeness affirmation, as well as changes to CMS’ monitoring and enforcement processes. Most notably, CMS now requires hospitals to use a standard format to comply with the machine-readable file requirement, which includes new data elements such as negotiated rate contracting type or methodology, an accuracy and completeness affirmation and (as of January 1, 2025) an “estimated allowed amount.” CMS also now requires that hospitals’ price transparency information be more easily found on their websites.</p><p>Regarding compliance and enforcement, hospitals may be required to have an authorized hospital official certify the accuracy and completeness of the hospital’s machine-readable file during the monitoring and enforcement process. CMS also can require hospitals to provide additional documentation at the agency’s request, including contracting documentation needed to validate the hospital’s negotiated rates and verification of the hospital’s licensing status.</p><p>In addition, CMS increased its efforts to publicize hospital-specific information on all compliance assessment and enforcement activity, which it now updates regularly on a public website. This includes details related to CMS’ assessment of hospital compliance, any compliance actions taken against a specific hospital, the status of the compliance action(s) and the outcome of the action(s). A list of the civil monetary compliance notices and fines issued to date is available on the CMS website.<sup>13 </sup>The fines vary in scope, from $55,000 to nearly $1 million, for those hospitals that have been deemed out of compliance with the Hospital Price Transparency Rule. CMS clearly has the authority and willingness to enforce compliance with the rule and assess significant fines, regardless of statutory activity.</p><h2>CONCLUSION</h2><p>Thank you for your consideration of the AHA’s comments on issues related to health care expenditures. We look forward to continuing to work with you to address these important topics on behalf of our patients and communities.</p><p>__________</p><p><sup>1 </sup><a class="ck-anchor" id="https://www.medpac.gov/wp-content/uploads/2023/10/MedPAC-MA-status-report-Jan-2024.pdf" href="https://www.medpac.gov/wp-content/uploads/2023/10/MedPAC-MA-status-report-Jan-2024.pdf">https://www.medpac.gov/wp-content/uploads/2023/10/MedPAC-MA-status-report-Jan-2024.pdf</a> <br><sup>2 </sup><a class="ck-anchor" id="https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf" href="https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf">https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf</a><br><sup>3 </sup><a class="ck-anchor" id="https://www.ama-assn.org/practice-management/prior-authorization/health-systems-plagued-payer-takeback-schemes-110000#:~:-%20text=authorization%E2%80%99s%20financial%20impact-,Prior%20authorization%E2%80%99s%20financial%20impact,an%20increase%20of%2067%.%E2%80%9D" href="https://www.ama-assn.org/practice-management/prior-authorization/health-systems-plagued-payer-takeback-schemes-110000#:~:-%20text=authorization%E2%80%99s%20financial%20impact-,Prior%20authorization%E2%80%99s%20financial%20impact,an%20increase%20of%2067%.%E2%80%9D">https://www.ama-assn.org/practice-management/prior-authorization/health-systems-plagued-payer-takeback-schemes-110000#:~:-%20text=authorization%E2%80%99s%20financial%20impact-,Prior%20authorization%E2%80%99s%20financial%20impact,an%20increase%20of%2067%.%E2%80%9D</a> <br><sup>4 </sup>AHA analysis of NHE projections of 2022-2031 expenditures.<br><sup>5 </sup><a class="ck-anchor" id="https://www.wsj.com/health/pharma/drugmakers-raise-prices-of-ozempic-mounjaro-and-hundreds-of-other-drugs-bdac7051" href="https://www.wsj.com/health/pharma/drugmakers-raise-prices-of-ozempic-mounjaro-and-hundreds-of-other-drugs-bdac7051">https://www.wsj.com/health/pharma/drugmakers-raise-prices-of-ozempic-mounjaro-and-hundreds-of-other-drugs-bdac7051</a> <br><sup>6 </sup><a class="ck-anchor" id="https://aspe.hhs.gov/reports/changes-list-prices-prescription-drugs" href="https://aspe.hhs.gov/reports/changes-list-prices-prescription-drugs">https://aspe.hhs.gov/reports/changes-list-prices-prescription-drugs</a> <br><sup>7</sup> <a class="ck-anchor" id="https://aspe.hhs.gov/reports/drug-shortages-impacts-consumer-costs" href="https://aspe.hhs.gov/reports/drug-shortages-impacts-consumer-costs">https://aspe.hhs.gov/reports/drug-shortages-impacts-consumer-costs</a> <br><sup>8</sup> <a class="ck-anchor" id="https://link.springer.com/article/10.1007/s13181-023-00950-6#:~:text=Shortages%20compromise%20or%20delay%20medical,morbidity%20%5B1%2C%202%5D." href="https://link.springer.com/article/10.1007/s13181-023-00950-6#:~:text=Shortages%20compromise%20or%20delay%20medical,morbidity%20%5B1%2C%202%5D.">https://link.springer.com/article/10.1007/s13181-023-00950-6#:~:text=Shortages%20compromise%20or%20delay%20medical,morbidity%20%5B1%2C%202%5D.</a> <br><sup>9 </sup><a class="ck-anchor" id="https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm" href="https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm">https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm</a> <br><sup>10 </sup><a class="ck-anchor" id="https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/" href="https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/">https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/</a> <br><sup>11</sup> <a class="ck-anchor" id="https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented" href="https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented">https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented</a> <br><sup>12 </sup><a class="ck-anchor" id="/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf" href="/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf">/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf</a><br><sup>13</sup> <a class="ck-anchor" id="https://www.cms.gov/priorities/key-initiatives/hospital-price-transparency/enforcement-actions" href="https://www.cms.gov/priorities/key-initiatives/hospital-price-transparency/enforcement-actions">https://www.cms.gov/priorities/key-initiatives/hospital-price-transparency/enforcement-actions</a> </p> Thu, 11 Jul 2024 13:11:00 -0500 Testimony /testimony/2024-07-10-aha-senate-statement-what-can-congress-do-end-medical-debt-crisis-america <p class="text-align-center"><strong>Statement</strong><br><strong>of the</strong><br><strong>şÚÁĎŐýÄÜÁż Association</strong><br><strong>for the</strong><br><strong>Committee on Health, Education, Labor & Pensions</strong><br><strong>of the</strong><br><strong>United States Senate</strong><br><strong>“What Can Congress Do to End the Medical Debt Crisis in America?”</strong><br><br><strong>July 11, 2024</strong><br> </p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) writes to share the hospital field’s comments on medical debt. While we appreciate Congress’s interest in addressing medical debt, we encourage policymakers to do more to prevent patients from incurring this type of debt, rather than focusing on credit reporting and alleviating acquired debt.</p><h2>OVERVIEW OF MEDICAL DEBT</h2><p>More Americans than ever are dealing with medical debt, a consequence of patients not paying some or all their health care bills, despite benefiting from the highest levels of insurance coverage in history. Unlike other types of debt, medical debt can be unexpected, due to an accident or illness. These debts can impact patients’ abilities to pay for necessities, including food, clothing and household items, and can result in patients using savings or loans to address their medical debt. Recent polling by the KFF found that “41% of adults have health care debt according to a broader definition, which includes health care debt on credit cards or owed to family members.”<sup>1 </sup>The survey also showed that:</p><ul><li>U.S. residents owe at least $220 billion in medical debt.</li><li>Approximately 14 million people (6% of adults) in the U.S. owe over $1,000 in medical debt.</li><li>About three million people (1% of adults) owe medical debt of more than $10,000.</li></ul><p>Hospitals and health systems are very concerned about patients’ medical debt. While health insurance is intended to be the primary mechanism to protect patients from unexpected and unaffordable health care costs, for too many that coverage is either unavailable or insufficient. Trends in health insurance coverage that are driving an increase in medical debt include inadequate enrollment in comprehensive health care coverage, growth in high-deductible and skinny health plans that intentionally push more costs onto patients and misleading health plan practices that confuse patients’ understanding of their coverage. These gaps in coverage leave individuals financially vulnerable when seeking medical care. The primary causes of medical debt include the following.</p><ul><li><strong>There are still too many uninsured Americans</strong>. Affordable, comprehensive health care coverage is the most important protection against medical debt. While the U.S. health care system has achieved higher coverage rates over the past decade, gaps remain.</li><li><strong>High deductibles subject many Americans to cost-sharing they cannot afford</strong>. High-deductible plans are designed to increase patients’ financial exposure through high cost-sharing in exchange for lower monthly premiums. Yet many individuals enrolled in high-deductible plans find they cannot manage their portion of health plan expenses. A Federal Reserve report found that 37% of adults could not afford a $400 emergency, an amount $1,000 less than the average general annual deductible for single, employer-sponsored coverage<sup>.2</sup></li><li><strong>Certain health plans provide inadequate benefits that frequently lead to surprise gaps in coverage</strong>. Short-term, limited-duration health plans and health-sharing ministries cover fewer benefits and include few to no consumer protections, such as required coverage of pre-existing conditions and limits on out-of-pocket costs. Patients with these types of plans often find themselves responsible for their entire medical bill without help from their health plan, including critical services such as emergency medical and oncology care. These denials can lead to an accumulation of significant medical debt.<sup>3</sup></li><li><strong>Complex health plan benefit design and misleading marketing can expose patients to unexpected costs</strong>. Many health plans have complex benefit designs that are not transparent to patients, such as what is covered pre-deductible, the interaction between point-of-service copays, coinsurance and deductibles, and poor communication and education about what the plan covers. For example, a recent National Association of Insurance Commissioners report found significant gaps and inconsistencies in how insurers share information about pre-deductible, no-cost-sharing preventive services with their members, resulting in a “meaningful barrier to effective understanding and use of preventive service benefits.”<sup>4</sup></li></ul><h2>HOSPITALS AND HEALTH SYSTEMS ADDRESSING DEBT</h2><p>Hospitals are the only part of the health care sector that provide services to patients regardless of their ability to pay. They underscore that commitment by offering financial and other assistance, including helping patients qualify for federal and state health care programs, such as Medicaid. In doing so, patients can receive regular preventive care, not just episodic care for serious injuries or illnesses. In addition, hospitals absorb billions of dollars of losses for patients who cannot pay their bills, mainly due to inadequate commercial insurance coverage; in 2020, the latest figure available, hospitals provided more than $42 billion in uncompensated care.<sup>5</sup></p><p>This is why hospitals are staunch supporters of ensuring everyone is enrolled in some form of comprehensive coverage. However, we appreciate that closing the remaining coverage gaps may be a longer-term solution and that more immediate steps can be taken. To that end, the AHA has routinely developed patient billing guidelines to help prevent patients from incurring medical debt. The AHA’s Board of Trustees adopted the most recent <a href="/standardsguidelines/2020-10-15-patient-billing-guidelines" target="_blank">set of guidelines</a> in 2020, which reaffirm the hospital field’s commitment to:</p><ul><li>Treating all people equitably, with dignity, respect and compassion.</li><li>Serving the emergency health care needs of all, regardless of a patient’s ability to pay.</li><li>Assisting patients who cannot pay for part or all the care they receive.</li></ul><p>Tax-exempt hospitals are also subject to a federal statute that requires written financial assistance and debt collection policies. These hospitals must wait at least 120 days after sending the initial bill to initiate extraordinary collections actions, notify the patient at least 30 days before taking the collections action and allow patients to submit financial aid applications for up to 240 days following the initial bill.</p><p>Several of the AHA’s guidelines directly address medical debt, including encouraging hospitals to forego adverse credit reporting of outstanding patient bills. So far, nearly 2,800 hospitals and health systems have affirmed their commitment to the guidelines, and the AHA revisits them regularly for updates.</p><p>Some hospitals are taking additional steps to help all eligible patients afford their medical bills, including using programs originally intended for the uninsured. These “presumptive eligibility” endeavors include proactively screening patients for financial assistance eligibility, regardless of insurance coverage or whether a patient has completed a financial aid application. The goal is to limit the need for hospitals to seek repayment by reducing patients’ financial liability to a more affordable amount.</p><h2>FEDERAL OVERSIGHT OF MEDICAL DEBT</h2><p>Policymakers at the federal level have acted to address the burden of medical debt through statutory changes, such as collection practices of tax-exempt hospitals, as well as those made through the Fair Debt Collection Practices Act, as overseen by the Consumer Financial Protection Bureau (CFPB), which impact how medical debt is displayed on credit reports. Recently, CFPB issued medical debt payment products and medical debt collection practices requests for information and a proposed rule to ban credit reporting agencies from incorporating medical debt when calculating credit scores.</p><p>While hospitals and health systems are assisting patients with their bills, policymakers must do more to prevent them from incurring these debts. Rather than focusing on debt relief grants or putting additional administrative burdens on providers, Congress must ensure patients can access comprehensive, affordable health insurance products.</p><p>Some of these suggested changes include:</p><ul><li> Restricting the sale of high-deductible health plans to only those individuals with the demonstrated means to afford the associated cost-sharing.</li><li>Prohibiting the sale of health-sharing ministry products and short-term limited-duration plans that go longer than 90 days.</li><li>Lowering the maximum out-of-pocket cost-sharing limits.</li><li>Eliminating the use of deductibles and co-insurance, and instead relying solely on flat co-payments which are easier for patients to anticipate and for providers to administer.</li><li>Removing providers from the collection of cost-sharing by requiring health plans to collect directly from their enrollees the cost-sharing payments they impose. This approach would eliminate most patient bills from providers altogether.</li></ul><p>Congress could also do more to improve health literacy by funding health navigators, community health workers and financial advisors to assist patients in selecting appropriate health insurance products.</p><h2>CONCLUSION</h2><p>Thank you for your consideration of the AHA’s comments on issues related to medical debt. We look forward to continuing to work with you to address these important topics on behalf of our patients and communities.</p><p>__________</p><p><small class="sm"><sup>1</sup> </small><a class="ck-anchor" id="https://www.healthsystemtracker.org/brief/the-burden-of-medical-debt-in-the-united-states/" href="https://www.healthsystemtracker.org/brief/the-burden-of-medical-debt-in-the-united-states/"><small class="sm">https://www.healthsystemtracker.org/brief/the-burden-of-medical-debt-in-the-united-states/</small></a><small class="sm"> </small><br><small class="sm"><sup>2</sup> </small><a class="ck-anchor" id="https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm" href="https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm"><small class="sm">https://www.federalreserve.gov/publications/2023-economic-well-being-of-us-households-in-2022-expenses.htm</small></a><br><small class="sm"><sup>3 </sup></small><a class="ck-anchor" id="https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/" href="https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/"><small class="sm">https://kffhealthnews.org/news/sham-sharing-ministries-test-faith-of-patients-and-insurance-regulators/</small></a><small class="sm"> </small><br><small class="sm"><sup>4</sup> </small><a class="ck-anchor" id="https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented/" href="https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented/"><small class="sm">https://healthyfuturega.org/ghf_resource/preventive-services-coverage-and-cost-sharing-protections-are-inconsistently-and-inequitably-implemented/</small></a><small class="sm"> </small><br><small class="sm"><sup>5</sup> </small><a class="ck-anchor" id="/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf" href="/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf"><small class="sm">/system/files/media/file/2020/01/2020-Uncompensated-Care-Fact-Sheet.pdf</small></a><small class="sm"> </small><br> </p> Wed, 10 Jul 2024 12:11:44 -0500 Testimony /testimony/2024-06-26-aha-house-statement-improving-value-based-care-patients-and-providers <p class="text-align-center"><strong>şÚÁĎŐýÄÜÁż Association</strong><br><br><strong>for the</strong><br><br><strong>Committee on Ways and Means</strong><br><br><strong>Subcommittee on Health</strong><br><br><strong>of the</strong><br><br><strong>U.S. House of Representatives</strong><br><br><strong>“Improving Value-Based Care for Patients and Providers”</strong><br><br><strong>June 26, 2024</strong></p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) appreciates the opportunity to provide feedback on the transition to value-based care.</p><h2>THE ROLE OF ALTERNATIVE PAYMENT MODELS IN VALUE-BASED CARE</h2><p>Our members support the U.S. health care system moving toward the provision of more outcomes-based, coordinated care and are continuing to redesign delivery systems to increase value and better serve patients. Over the last 14 years, many of our hospital and health system members have participated in a variety of alternative payment models (APMs).</p><p>While the movement to value holds tremendous promise, the transition has been slower than anticipated and more needs to be done to drive long-term system transformations.</p><p>There are principles that we believe should guide the development of APM design to make participation more attractive for potential participants. These include:</p><ul><li><strong>Appropriate On-ramp and Glidepath to Risk</strong>. Model participants should have an adequate on-ramp and glidepath to transition to risk. They must have adequate time to implement care delivery changes (integrating new staff, changing clinical workflows, implementing new analytics tools, etc.) and review data prior to initiating the program.</li><li><strong>Adequate Risk Adjustment</strong>. Models should include adequate risk adjustment methodologies to account for social needs and clinical complexity. This will ensure models do not inappropriately penalize participants treating the sickest, most complicated and underserved patients.</li><li><strong>Voluntary Participation and Flexible Design</strong>. Model designs should be flexible, incorporating features such as voluntary participation, the ability to choose individual clinical episodes, the ability to add components/waivers and options for participants to leave the model(s).</li><li><strong>Balanced Risk Versus Reward</strong>. Models should also balance the risk versus reward in a way that encourages providers to take on additional risk but does not penalize those that need additional time and experience before they are able to do so. A glidepath approach should be implemented, gradually migrating from upside only to downside risk.</li><li><strong>Guardrails to Ensure Hospitals Do Not Compete Against Their Own Best Performance</strong>. Models should provide guardrails to ensure that participants are not penalized over time when they achieve optimal cost savings and outcomes performance. Participants must have incentives to remain in models for the long-term.</li><li><strong>Resources to Support Initial Investment</strong>. Upfront investment incentives should be provided to support organizations in their transition to value-based payment. For example, to be successful in such models, hospitals, health systems and provider groups must invest in additional staffing and infrastructure to support care delivery redesign and outcomes tracking.</li><li><strong>Transparency</strong>. Models’ methodology, data and design elements should be transparently shared with all potential participants. Proposed changes should be vetted with stakeholders.</li><li><strong>Adequate Model Duration</strong>. Models should be long enough in duration to truly support care delivery transformation and assess the impact on outcomes. Historically, models have been too short and/or have had multiple, significant design changes even within the designated duration, making it difficult for participants to self-evaluate and change course when necessary.</li><li><strong>Timely Availability of Data</strong>. Model participants should have readily available, timely access to data about their patient populations. We would encourage the dedication of resources from the Centers for Medicare & Medicaid Services (CMS) (staff and technology) to provide program participants with more complete data as close to real-time as possible.</li><li><strong>Waivers to Address Barriers to Clinical Integration and Care Coordination</strong>. This entails waiving Medicare program regulations that frequently inhibit care coordination and work against participants’ efforts to ensure that care is provided in the right place at the right time.</li></ul><h2>POLICIES TO SUPPORT HOSPITAL TRANSITIONS TO VALUE-BASED CARE</h2><p><strong>Extension of Advanced APM Incentive Payments</strong>. The bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was also intended to support the transition to value-based care. MACRA provided advanced incentive payments (5%) for providers participating in advanced APMs through 2024. These payments were designed to assist with the provision of non-fee-for-service programs like meal delivery programs, transportation services, digital tools and care coordinators which promote population health, among other services.</p><p>However, MACRA statute only provided the advanced APM bonuses through the calendar year (CY) 2024 payment period. We appreciate Congress acting through a provision in the Consolidated Appropriations Act (CAA) of 2023 to extend the advanced APM incentive payments at 3.5% for the CY 2025 payment period and again in the CAA of 2024 to extend through 2026 at 1.88%.</p><p>While lower than the current 5% incentive payment rate, the incentive provides crucial resources. Because participation in the advanced APM program has fallen short of initial projections, spending on advanced APM bonuses has fallen well short of the amount the Congressional Budget Office projected when MACRA was originally scored. Repurposing the spending shortfall for APM bonuses in future years will serve to accelerate our shared goal of increasing APM adoption. <strong>We urge the extension of these incentive payments.</strong></p><p><strong>Eliminate Low-Revenue/High-Revenue Qualifying Criteria.</strong> Congress also should urge CMS to eliminate its designation of ACOs as either low- or high-revenue. The agency has used this label as a proxy measure to, for example, determine if an organization is supporting underserved populations and/or if the organization is physician-led to qualify for advance investment payments. Yet, there is no valid reason to conclude that this delineation, which measures an accountable care organization’s (ACO) amount of “captured” revenue, is an accurate or appropriate predictor of whether it treats an underserved region. In fact, analysis suggests that critical access hospitals, federally qualified health centers and rural health centers are predominantly classified as high-revenue. Further, both low- and high-revenue ACOs are working to address health equity as part of their care transformation work; assistance investing in these efforts would help across the board. <strong>We urge the removal of problematic high/low revenue thresholds that preclude rural and critical access hospitals from obtaining necessary resources for infrastructure investment.</strong></p><p><strong>Support Investment in Resources for Rural Hospitals</strong>. Congress should encourage CMS to continue its resources and infrastructure investment to support rural hospitals’ transition to APMs. According to a Government Accountability Office report, only 12% of eligible rural providers in 2019 participated in the advanced APM program; of those that participated, just 6% of rural providers participated in two or more advanced APMs, compared to 11% of those not in rural areas. These models are often not designed in ways that allow broad rural participation, and the AHA supports continued efforts to better support rural hospitals’ migration to advanced APM models. In particular, the <strong>AHA since 2021 has supported the establishment of a Rural Design Center within the Center for Medicare and Medicaid Innovation (CMMI), which would focus on smaller-scale initiatives to meet rural communities’ needs and encourage participation of rural hospitals and facility types. A Rural Design Center would help develop and increase the number of new rural-focused CMMI demonstrations, expand existing rural demonstrations and create separate rural tracks within new or existing CMMI models.</strong></p><p><strong>We support the Value in Health Care Act (H.R. 5013/S. 3503), which would extend incentive payments, remove revenue distinctions and improve financial benchmarks to ensure participants are not penalized for success.</strong></p><h2>RECENT CENTER FOR MEDICARE AND MEDICAID INNOVATION (CMMI) MODELS</h2><p><strong>Proposed Transforming Episode Accountability Model</strong>. On April 10, as part of the inpatient prospective payment system (PPS) proposed rule, the CMMI proposed a new mandatory payment model — Transforming Episode Accountability Model (TEAM) — that would bundle payment to acute care hospitals for five types of surgical episode categories: coronary artery bypass graft, lower extremity joint replacement, major bowel procedure, surgical hip/femur fracture treatment and spinal fusion. It would make acute care hospitals responsible for the quality and cost of all services provided during select surgical episodes, from the date of inpatient admission or outpatient procedure through 30 days post-discharge.</p><p>The AHA has significant concerns with the TEAM payment model. We are supportive of the Department of Health and Human Services Secretary’s goal of moving toward more accountable, coordinated care through new APMs. However, CMS is proposing to mandate a model that has significant design flaws, and as proposed places too much risk on providers with too little opportunity for reward in the form of shared savings, especially considering the significant upfront investments required. If CMS cannot make extensive changes to the model, it should not implement it at this time. To do so would make TEAM no more than a thinly disguised payment cut, as it fails to provide hospitals a fair opportunity to achieve enough savings to garner a reconciliation payment.</p><p>The proposal does not align with the principles we outlined above. For example, we have previously commented on the necessity for waivers to support care coordination, more gradual glidepaths to two-sided risk and reasonable discount factors to ensure financial viability. If anything, TEAM is a step backward with fewer waivers, shorter timelines to assume downside risk and more aggressive discount factors that make cost savings more challenging.</p><p>Moreover, the tremendous scope of this rule and its aggressive 60-day comment period made it challenging to fully evaluate and analyze the proposal and its significant impact on hospitals and health systems. The five types of surgical procedures proposed for inclusion in TEAM comprise over 11% of inpatient PPS payments in 2023 — a staggering amount that does not even include the outpatient payments that would be at risk as part of the model. While the AHA worked closely with our hospital and health system members to assess the potential impact of TEAM on the important work they do in caring for their patients and communities, the incredibly short comment period severely hampered our ability to provide comprehensive comments.</p><p>We strongly recommend that CMS make TEAM voluntary, lower the 3% discount factor and make several changes to problematic design elements.</p><p><strong>Proposed Increasing Organ Transplant Access Model</strong>. Just four weeks after TEAM was proposed, CMS proposed another mandatory payment model for kidney transplants. The Increasing Organ Transplant Access (IOTA) model would test whether performance-based incentives or penalties for participating transplant hospitals would increase access to kidney transplants for patients with end-stage renal disease while preserving or enhancing quality of care, improving equitable access to kidney transplant care and reducing Medicare expenditures. The model would run for six years, beginning Jan. 1, 2025. Hospitals eligible for participation would include non-pediatric transplant facilities conducting at least 11 kidney transplants during a three-year baseline period. It is anticipated that 90 hospitals would be required to participate.</p><p>While we appreciate CMMI’s goals of increasing access to kidney transplants, we are again left questioning the model design elements and are concerned that the model as written may have unintended consequences by focusing so heavily on volume (namely sub-par matches). Also, as mentioned above, implementation of complex payment models requires significant time, resources and staffing on the part of hospital participants. But CMMI has proposed a start date of Jan. 1, 2025. Given the transformation that is already occurring nationally under provisions of the Organ Procurement and Transplantation Network Act, this aggressive timeline is untenable. Additionally, we are concerned that CMMI is again proposing mandatory participation. As mentioned in our principles, it is critical that organizations can assess whether models are appropriate to best serve the needs of their patients and communities. Therefore, participation should be voluntary.</p><h2>CONCLUSION</h2><p>The APM model design principles we outlined above would support more organizations’ abilities to provide accountable and coordinated care. The AHA urges Congress to extend APM incentive payments, for CMS to remove problematic high- and low-revenue thresholds that preclude rural and critical access hospitals from obtaining necessary resources for infrastructure investment, and for CMMI to make models such as TEAM and IOTA voluntary.</p><p>The AHA appreciates your efforts to examine these issues, and we look forward to working with you.</p> Wed, 26 Jun 2024 15:38:30 -0500 Testimony /testimony/2024-06-13-aha-statement-energy-and-commerce-subcommittee-assessing-value-based-care <p class="text-align-center"><strong>Statement</strong></p><p class="text-align-center"><strong>of the</strong></p><p class="text-align-center"><strong>şÚÁĎŐýÄÜÁż Association</strong></p><p class="text-align-center"><strong>for the</strong></p><p class="text-align-center"><strong>Committee on Energy and Commerce</strong></p><p class="text-align-center"><strong>Subcommittee on Health</strong></p><p class="text-align-center"><strong>of the</strong></p><p class="text-align-center"><strong>U.S. House of Representatives</strong></p><p class="text-align-center"><strong>“Checking-In on CMMI: Assessing the Transition to Value-Based Care”</strong></p><p class="text-align-center"><strong>June 13, 2024</strong></p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) appreciates the opportunity to provide feedback on the transition to value-based care.</p><h2>THE ROLE OF ALTERNATIVE PAYMENT MODELS IN VALUE-BASED CARE</h2><p>Our members support the U.S. health care system moving toward the provision of more outcomes-based, coordinated care and are continuing to redesign delivery systems to increase value and better serve patients. The AHA appreciates the Centers for Medicare & Medicaid Services’ (CMS) continued efforts to develop innovative payment models to reward providers based on outcomes rather than patient volume. </p><p>Over the last 14 years, many of our hospital and health system members have participated in a variety of alternative payment models (APMs) developed by the Center for Medicare and Medicaid Innovation (CMMI). Some APMs have generated net savings for taxpayers while maintaining quality of care for patients.</p><p>While the movement to value holds tremendous promise, the transition has been slower than anticipated and more needs to be done to drive long-term system transformations. CMMI plays a critical role in ensuring that hospitals and providers are set up for success in the various models they deploy. But some of the CMMI models were designed with requirements that made implementation exceedingly difficult and success even more so.</p><p>There are principles that we believe should guide the development of APM design. These include:</p><ul><li><strong>Appropriate On-ramp and Glidepath to Risk.</strong> Model participants should have an adequate on-ramp and glidepath to transition to risk. They must have adequate time to implement care delivery changes (integrating new staff, changing clinical workflows, implementing new analytics tools, etc.) and review data prior to initiating the program.</li><li><strong>Adequate Risk Adjustment.</strong> Models should include adequate risk adjustment methodologies to account for social needs and clinical complexity. This will ensure models do not inappropriately penalize participants treating the sickest, most complicated and underserved patients.</li><li><strong>Voluntary Participation and Flexible Design.</strong> Model designs should be flexible, incorporating features such as voluntary participation, the ability to choose individual clinical episodes, the ability to add components/waivers and options for participants to leave the model(s).</li><li><strong>Balanced Risk Versus Reward.</strong> Models should also balance the risk versus reward in a way that encourages providers to take on additional risk but does not penalize those that need additional time and experience before they are able to do so. A glidepath approach should be implemented, gradually migrating from upside only to downside risk.</li><li><strong>Guardrails to Ensure Hospitals Do Not Compete Against Their Own Best Performance.</strong> Models should provide guardrails to ensure that participants are not penalized over time when they achieve optimal cost savings and outcomes performance. Participants must have incentives to remain in models for the long-term.</li><li><strong>Resources to Support Initial Investment.</strong> Upfront investment incentives should be provided to support organizations in their transition to value-based payment. For example, to be successful in such models, hospitals, health systems and provider groups must invest in additional staffing and infrastructure to support care delivery redesign and outcomes tracking.</li></ul><p>To ensure that these and other practical considerations are appropriately included in CMMI models, we believe the agency would benefit enormously from consulting an advisory group of hospital and health system leaders who are managing or have managed the kind of organizations that would be part of the models CMS is trying to build.</p><h2>TEAM PROPOSED PAYMENT MODEL</h2><p>On April 10, as part of the inpatient prospective payment system (PPS) proposed rule, the CMMI proposed a new mandatory payment model — Transforming Episode Accountability Model (TEAM) — that would bundle payment to acute care hospitals for five types of surgical episode categories: coronary artery bypass graft, lower extremity joint replacement, major bowel procedure, surgical hip/femur fracture treatment and spinal fusion. It would make acute care hospitals responsible for the quality and cost of all services provided during select surgical episodes, from the date of inpatient admission or outpatient procedure through 30-days post-discharge.</p><p>The AHA has significant concerns with the TEAM payment model. We are supportive of the Department of Health and Human Services Secretary’s goal of moving toward more accountable, coordinated care through new APMs. However, CMS is proposing to mandate a model that has significant design flaws, and as proposed places too much risk on providers with too little opportunity for reward in the form of shared savings, especially considering the significant upfront investments required. If CMS cannot make extensive changes to the model, it should not implement it at this time. To do so would make TEAM no more than a thinly disguised payment cut, as it fails to provide hospitals a fair opportunity to achieve enough savings to garner a reconciliation payment.</p><p>The proposal does not align with the principles we outlined above. For example, we have previously commented on the necessity for waivers to support care coordination, more gradual glidepaths to two-sided risk and reasonable discount factors to ensure financial viability. If anything, TEAM is a step backward with fewer waivers, shorter timelines to assume downside risk and more aggressive discount factors that make cost savings more challenging.</p><p>Moreover, the tremendous scope of this rule and its aggressive 60-day comment period made it challenging to fully evaluate and analyze the proposal and its significant impact on hospitals and health systems. The five types of surgical procedures proposed for inclusion in TEAM comprise over 11% of inpatient PPS payments in 2023 — a staggering amount that does not even include the outpatient payments that would be at risk as part of the model. While the AHA worked closely with our hospital and health system members to assess the potential impact of TEAM on the important work they do in caring for their patients and communities, the incredibly short comment period severely hampered our ability to provide comprehensive comments.</p><p>We strongly recommend that CMS make TEAM voluntary, lower the 3% discount factor and make several changes to problematic design elements.</p><h2>INCREASING ORGAN TRANSPLANT ACCESS PROPOSED MODEL</h2><p>Just four weeks after TEAM was proposed, CMS proposed another mandatory payment model for kidney transplants. The Increasing Organ Transplant Access (IOTA) model would test whether performance-based incentives or penalties for participating transplant hospitals would increase access to kidney transplants for patients with end-stage renal disease while preserving or enhancing quality of care, improving equitable access to kidney transplant care and reducing Medicare expenditures. The model would run for six years, beginning Jan. 1, 2025. Hospitals eligible for participation would include non-pediatric transplant facilities conducting at least 11 kidney transplants during a three-year baseline period. It is anticipated that 90 hospitals would be required to participate.</p><p>While we appreciate CMMI’s goals of increasing access to kidney transplants, we are again left questioning the model design elements and are concerned that the model as written may have unintended consequences by focusing so heavily on volume (namely sub-par matches). Also, as mentioned above, implementation of complex payment models requires significant time, resources and staffing on the part of hospital participants. But CMMI has proposed a start date of Jan. 1, 2025. Given the transformation that is already occurring nationally under provisions of the Organ Procurement and Transplantation Network Act, this aggressive timeline is untenable. Additionally, we are concerned that CMMI is again proposing mandatory participation. As mentioned in our principles, it is critical that organizations can assess whether models are appropriate to best serve the needs of their patients and communities. Therefore, participation should be voluntary.</p><h2>CONCLUSION</h2><p>Again, the AHA supports the health care system moving toward the provision of more accountable, coordinated care. We recognize the critical role CMMI plays in advancing innovative payment models. We have recommended principles that should guide the development of APM model design and are concerned that recent model proposals such as TEAM and IOTA are steps backwards. The AHA appreciates your efforts to examine these issues, and we look forward to working with you.</p> Thu, 13 Jun 2024 08:35:50 -0500 Testimony /testimony/2024-05-23-aha-statement-senate-committee-physician-well-being-pediatric-emergency-care-acts <p class="text-align-center"><strong>Statement</strong><br><strong>of the</strong><br><strong>şÚÁĎŐýÄÜÁż Association</strong><br><strong>for the</strong><br><strong>Committee on Health, Education, Labor & Pensions</strong><br><strong>of the</strong><br><strong>U.S. Senate</strong><br><br><strong>"Executive Session on S. 3679, Dr. Lorna Breen Health Care Provider Protection Reauthorization Act and S. 3765, Emergency Medical Services for Children Reauthorization Act of 2024”</strong></p><p class="text-align-center"><strong>May 23, 2024</strong></p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) appreciates the opportunity to provide comments on legislation to be considered at the committee’s executive session on May 23, 2024.</p><p><strong>Dr. Lorna Breen Health Care Provider Protection Reauthorization Act (S. 3679).</strong><br>For decades, health care professionals have faced greater rates of mental and behavioral health conditions, suicide and burnout than other professions while fearing the stigma and potential career repercussions of seeking care. The COVID-19 pandemic exacerbated the already-present issues of stress, depression, anxiety and other mental health issues experienced by health care providers.</p><p>The AHA supports S. 3679, the Dr. Lorna Breen Health Care Provider Protection Reauthorization Act that addresses this mental health crisis among our nation’s healers. The law is intended to reduce and prevent suicide, burnout, and mental and behavioral health conditions among health care providers. The act would reauthorize grants to health care providers to establish programs that offer behavioral health services for front-line workers as well as a national education and awareness campaign that provides health leaders with evidence-based solutions to reduce health care worker burnout.</p><p><strong>Emergency Medical Services for Children Reauthorization Act of 2024 (S. 3765)</strong>. The AHA supports S. 3765 which reauthorizes the Emergency Medical Services for Children Program for an additional five years to provide specialized emergency care for children through availability of child-appropriate equipment in ambulances and emergency departments. In addition, the program supports training programs to prevent injuries to children and to educate emergency medical technicians, paramedics and other emergency medical care providers.</p><p>We thank you for your leadership on behalf of the nation’s health care workforce, and we look forward to working with you to enact these important pieces of legislation.</p> Thu, 23 May 2024 09:56:38 -0500 Testimony /testimony/2024-05-23-aha-statement-house-budget-committee-value-hospital-systems <p class="text-align-center"><strong>Statement</strong><br><strong>of the</strong><br><strong>şÚÁĎŐýÄÜÁż Association</strong><br><strong>for the</strong><br><strong>Committee on the Budget</strong><br><strong>of the</strong><br><strong>U.S. House of Representatives</strong></p><p class="text-align-center"><strong>“Breaking Up Health Care Monopolies: Examining the Budgetary Effects of Health Care Consolidation”</strong></p><p class="text-align-center"><strong>May 23, 2024</strong></p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) writes to share the hospital perspective on the ways hospital mergers and acquisitions can expand and preserve access to quality care.</p><h2>MERGERS AND ACQUISITIONS HELP HOSPITALS MANAGE ONGOING FINANCIAL PRESSURES</h2><p>Hospitals and health systems continue to experience significant financial pressures that challenge their ability to provide 24/7 care for the patients and communities they serve. Mergers and acquisitions allow some hospitals use to manage these pressures and increase access to care for patients.</p><p>A <a href="/system/files/media/file/2024/05/Americas-Hospitals-and-Health-Systems-Continue-to-Face-Escalating-Operational-Costs-and-Economic-Pressures.pdf">recent report</a> released by the AHA details the extraordinary financial pressures continuing to affect access to patient care. In 2023, hospitals and health systems again sustained substantial expenses due to high costs for labor, drugs and supplies, ongoing workforce challenges and growing administrative burdens. At the same time, hospitals and health systems increasingly encounter the twin challenges of navigating onerous commercial insurer practices that deny and delay payment for care provided to patients, while reimbursements from Medicare and Medicaid have failed to keep pace with mounting costs.</p><p>Merging with a hospital system can help some hospitals ease these financial burdens and improve patient care. Among other benefits, mergers are a tool that expand access to care for patients and allow hospitals to achieve the scale and increase the efficiency in purchasing medical services, supplies and prescription drugs. Mergers also help to reduce other operational costs through shared service models for departments like information technology (IT), human resources, finance and compliance. Hospitals and health systems should be permitted to pursue the type of arrangements that work best for their patients and community, including independent status, mergers or other partnerships.</p><h2>BENEFITS OF HOSPITAL MERGERS AND ACQUISITIONS TO PATIENTS AND COMMUNITIES</h2><p>Hospital mergers and acquisitions bring measurable benefits to patients and communities, including increased access to care, improved quality and lower health care costs.</p><h3>Better Access to Care</h3><p>Mergers and acquisitions also play a critical role in preserving access to care, especially for patients and hospitals in rural or other underserved communities. In particular, they help hospitals improve access to care by expanding the types of specialists and services available to patients. According to an analysis by the health care consulting firm Kaufman Hall, nearly 40% of affiliated hospitals added one or more services post-acquisition. Almost half of all hospitals acquired by an academic medical center added one or more service. Patients at hospitals acquired by academic medical centers or large health systems also gained improved access to tertiary and quaternary services.<sup>1</sup></p><p>Mergers and acquisitions also are a vital tool that some health systems use to keep financially struggling hospitals open and serving their communities, thereby averting bankruptcy or even closure. When hospitals become part of a health system, the acquired hospital can more easily and cohesively access services and specialties available at other hospitals within the system. As a result, the continuum of care is strengthened for patients and the community, resulting in better care, increased access to specialty care and decreased readmission rates overall.</p><p>This is particularly true in rural and underserved communities. Health systems typically acquire hospitals in these communities when the hospitals are under financial distress.  The results are demonstrable. Research has shown that rural hospitals are less likely to close after acquisition compared to independent hospitals and that mergers have improved access and quality of care for rural hospitals.<sup>2</sup></p><h3>Improved Quality</h3><p>Emerging research has demonstrated a clear association between consolidation and quality improvement, indicating that hospital mergers and acquisitions may lead to better quality of care. For example, one study found that a full-integration approach is associated with improvements in mortality and readmission rates, among other quality and outcome improvements.<sup>3</sup> This is due to quality improvement in part due to the integration of information technology and analytic-driven interventions, both made possible by leveraging the health systems resources in the acquired hospital. Another study found significant reductions in mortality for a number of common conditions — including acute myocardial infarction, heart failure, acute stroke and pneumonia — among patients at rural hospitals that had merged or been acquired.<sup>4</sup></p><h3>Lower Health Care Costs</h3><p>Mergers and acquisitions help reduce health care costs and are an effective tool for hospitals to operate more efficiently and cope with escalating costs. For example, a Charles River Associates analysis for the AHA shows that hospital acquisitions are associated with a statistically significant 3.3% reduction in annual operating expenses per admission at acquired hospitals, along with a 3.7% decrease in net patient revenue per adjusted admission.<sup>5</sup></p><p>The same report shows that additional benefit come from improved IT systems and advanced data analytics. Merged hospitals can often better invest in IT infrastructure for both clinical and financial data that can be used to identify best practices for more cost-effective, integrated and streamlined care. These data systems have substantial, but largely, fixed costs, making them effectively inaccessible to independent hospitals but scalable for larger systems.</p><h5>INSURERS LEVERAGE THEIR MARKET POWER AT THE EXPENSE OF HOSPITALS AND HEALTH SYSTEMS</h5><p>Hospitals and health systems face significant pressure from health insurance companies, which are leveraging their market power in a way that drives up hospital and health system costs. For example, in nearly half of all markets, a single health insurer controls at least 50% of the commercial market.<sup>6</sup> Commercial health insurers can — and do — use this market power to increase health insurance premiums as research has found that marketplace insurance premiums grow faster in areas with less insurer competition.<sup>7</sup> Commercial insurers also have used their market power to implement policies that compromise patient safety and raise costs for hospitals and patients alike, such as prior authorization delays, denying coverage for medically necessary care, or forcing patients to try potentially ineffective treatments or therapies.<sup>8</sup></p><p>Due to burnout associated with commercial insurer policies like prior authorization and low reimbursement rates, most physicians are choosing to become employed rather than operate their own practices. While a disproportionate amount of attention has been placed on hospitals’ acquisition of physician practices, large commercial insurers including CVS Health and UnitedHealth Group have recently spent billions of dollars acquiring practices. In fact, non-hospital entities including health insurers have acquired 90% of physician practices over the last five years. <sup>9</sup> We urge this committee to examine the costs and impact on health care access and affordability associated with this widespread acquisition of America’s physicians by corporate health insurance companies.</p><p>We are concerned that the scope of major commercial insurers increases costs in the heath care system. Studies have shown that highly concentrated insurer markets are associated with higher premiums and that insurers are not likely to pass on to consumers any savings achieved through lower provider rates.<sup>10 </sup>We urge Congress to examine these issues and their impact on health care delivery for patients across the country.</p><h5>MISGUIDED LEGISLATIVE PROPOSALS WILL REDUCE ACCESS TO CARE</h5><p>We are concerned that certain legislative proposals that claim to increase competition in health care — including those that would create additional Medicare site-neutral payment cuts and ease growth restrictions on physician-owned hospitals — would jeopardize access to care for patients.</p><h3>Site-neutral Payment Reductions</h3><p>The AHA strongly opposes efforts to expand site-neutral payment cuts. Current Medicare payment rates appropriately recognize that there are fundamental differences between patient care delivered in hospital outpatient departments (HOPDs) compared to other settings. HOPDs provide important access to care for Medicare beneficiaries, many of which are more likely to be sicker and more medically complex than those treated at physicians’ offices, while also being held to stricter safety and regulatory requirements.</p><p>The cost of care delivered in hospitals and health systems considers the unique benefits they provide to their communities, which are not provided by other sites of care. This includes investments made to maintain standby capacity for natural and manmade disasters, public health emergencies and unexpected traumatic events, as well as delivering 24/7 emergency care to all who come to the hospital.</p><p>Existing site-neutral payment cuts have already created significant financial challenges for many hospitals and health systems. This is largely because Medicare underpays hospitals for the cost of caring for patients. The latest <a href="/2024-01-10-infographic-medicare-significantly-underpays-hospitals-cost-patient-care">analysis</a> shows that on average Medicare pays only 82 cents for every dollar of hospital care provided to Medicare beneficiaries, leaving hospitals with nearly $100 billion in Medicare shortfalls in 2022 alone. As a result, two-thirds of all hospitals reported negative Medicare margins in 2022. Any additional site-neutral cuts would exacerbate these financial challenges and further reduce access to essential care and services in communities.</p><h3>Physician-owned Hospitals</h3><p>America’s community hospitals and health systems welcome fair competition, where health care entities can compete based on quality, price, safety and patient satisfaction. But physician-owned hospitals (POH) — where physicians select the healthiest and best-insured patients and self-refer those patients to facilities in which they have an ownership interest — represent the antithesis of competition.</p><p>POHs provide limited emergency services, are ill-equipped to respond to public health crises, and they increase costs for patients, other providers, and the federal government. The <a href="https://www.cbo.gov/sites/default/files/111th-congress-2009-2010/costestimate/amendreconprop.pdf" target="_blank">Congressional Budget Office</a>, the <a href="https://www.medpac.gov/wp-content/uploads/import_data/scrape_files/docs/default-source/reports/Mar05_SpecHospitals.pdf" target="_blank">Medicare Payment Advisory Commission</a> and the <a href="https://public-inspection.federalregister.gov/2023-16252.pdf" target="_blank">Centers for Medicare & Medicaid Services</a> all have concluded that physician self-referral leads to greater per capita utilization of services and higher costs for the Medicare program, among other negative impacts.</p><p>The AHA strongly opposes any changes to current law that would either expand the number of POHs or ease restrictions on the growth of existing facilities. Allowing more POHs in rural areas could be particularly destabilizing because these areas already have a limited patient population, with hospitals struggling to maintain fixed-operating costs.</p><h2>GREATER COMMERCIAL INSURER ACCOUNTABILITY IS NEEDED</h2><p>We urge Congress to address harmful practices from commercial insurers like prior authorization that lead to delays in patient care and increase costs and burdens to hospitals and health systems. Inappropriate denials for prior authorization and coverage of medically necessary services are a pervasive problem among certain plans in the Medicare Advantage program. This results in delays in care, wasteful and potentially dangerous utilization of fail-first requirements for imaging and therapies, and other direct patient harms. These practices also add financial burden and strain to the health care system through inappropriate payment denials and increased costs to comply with plan requirements.</p><p>The AHA supports regulations and legislative solutions that streamline and improve prior authorization processes, including the Improving Seniors’ Timely Access to Care Act, which would codify many of the reforms in the Interoperability and Prior Authorization final rule.</p><h2>CONCLUSION</h2><p>The AHA appreciates your efforts to examine this issue and looks forward to continuing to work with you.</p><p>__________</p><p><sup>1</sup> <a href="/system/files/media/file/2021/10/KH-AHA-Benefits-of-Hospital-Mergers-Acquisitions-2021-10-08.pdf">/system/files/media/file/2021/10/KH-AHA-Benefits-of-Hospital-Mergers-Acquisitions-2021-10-08.pdf</a> <br><sup>2</sup> <a href="https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9250050/">https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9250050/</a> </p><p><sup>3</sup><a href="https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2787652">https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2787652</a></p><p><sup>4</sup><a href="https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2784342">https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2784342</a></p><p><sup>5</sup><a href="/guidesreports/2021-08-18-hospital-merger-benefits-econometric-analysis-revisited-executive-summary">/guidesreports/2021-08-18-hospital-merger-benefits-econometric-analysis-revisited-executive-summary</a></p><p><sup>6</sup><a href="https://www.ama-assn.org/delivering-care/patient-support-advocacy/competition-health-care-research">https://www.ama-assn.org/delivering-care/patient-support-advocacy/competition-health-care-research</a> </p><p><sup>7</sup> <a href="https://www.healthaffairs.org/doi/10.1377/hlthaff.2018.0054">https://www.healthaffairs.org/doi/10.1377/hlthaff.2018.0054</a></p><p><sup>8</sup><a href="/white-papers/2022-07-28-commercial-health-plans-policies-compromise-patient-safety-and-raise-costs">/white-papers/2022-07-28-commercial-health-plans-policies-compromise-patient-safety-and-raise-costs</a></p><p><sup>9</sup><a href="/system/files/media/file/2023/06/Private-Equity-and-Health-Insurers-Acquire-More-Physicians-than-Hospitals-Infographic.pdf">/system/files/media/file/2023/06/Private-Equity-and-Health-Insurers-Acquire-More-Physicians-than-Hospitals-Infographic.pdf</a> </p><p><sup>10</sup><a href="https://www.healthaffairs.org/doi/10.1377/hlthaff.2015.0548">https://www.healthaffairs.org/doi/10.1377/hlthaff.2015.0548</a> <br> </p> Thu, 23 May 2024 08:30:54 -0500 Testimony /2024-05-22-aha-statement-house-ways-and-means-subcommittee-physician-practice-consolidation <p class="text-align-center"><strong>Statement</strong><br><strong>of the</strong><br><strong>şÚÁĎŐýÄÜÁż Association</strong><br><strong>for the</strong><br><strong>Committee on Ways and Means</strong><br><strong>Subcommittee on Health</strong><br><strong>of the</strong><br><strong>U.S. House of Representatives</strong></p><p class="text-align-center"><strong>“The Collapse of Private Practice: Examining the Challenges Facing Independent Medicine”</strong></p><p class="text-align-center"><strong>May 23, 2024</strong></p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the şÚÁĎŐýÄÜÁż Association (AHA) appreciates the opportunity to provide our perspective on the financial and regulatory burdens facing physician practices.</p><h2>FACTORS DRIVING PHYSICIAN PRACTICE ACQUISITIONS</h2><p>Much like hospitals and health systems, physicians across the country are facing increased costs, inadequate reimbursements and administrative burdens from public and private insurer practices. These factors create major barriers to operating an independent physician practice. As a result, physicians are increasingly looking for alternative practice settings that will provide financial security so they can focus more on clinical care and less on managing their own practice. Hospitals and health systems are an appropriate partner to help physicians alleviate many of these burdens.</p><h3>Commercial Insurer Policies and Practices</h3><p>Onerous policies from commercial health insurers have spurred many physicians to seek employment instead of maintaining their own practices. According to a recent survey of physicians conducted by Morning Consult on behalf of the AHA, 84% of employed physicians reported that administrative burden from payers — including prior authorization and reporting requirements — has adversely impacted their ability to operate an independent practice.<sup>1</sup> In the same survey, 81% of physicians reported that commercial insurer policies and practices interfered with their ability to practice medicine.<sup>2</sup></p><p>Excessive prior authorization requirements and inappropriate denials of coverage for medically necessary services are a pervasive problem among certain plans in the Medicare Advantage (MA) program. These insurer practices result in delays in care and add financial burden and strain to the health care system, including increased staffing and technology costs to comply with plan requirements. Additionally, the administrative burden of prior authorization requirements and processes further strain the health care workforce and contribute to provider burnout. In fact, Surgeon General Vivek Murthy, M.D., issued a recent advisory that notes that burdensome documentation requirements, including the volume of and requirements for prior authorization, are drivers of health care worker burnout.<sup>3</sup></p><h3>Escalating Costs</h3><p>Managing a physician practice often includes significant operational costs associated with maintaining electronic health records and patient portals, processing billing and claims submissions, including managing prior authorization requirements, and office rent, among other expenses. The costs associated with these requirements range from $20 for a primary care office visit to as high as $215 for a procedure at an inpatient surgical center.<sup>4</sup></p><p>Compounding that problem, low reimbursement rates from public payers like Medicare and Medicaid are another barrier to the practice of medicine in a private practice setting. Reimbursement updates have failed to account for rising inflation and increasing input costs like supply chain disruptions and workforce shortages. Appropriately accounting for these trends is essential to ensure that Medicare payments for professional services more accurately reflect the cost of providing care. Medicare physician payment was effectively cut 26%, adjusted for inflation, from 2001 to 2023.<sup>5</sup> The widening gap between inflation and physician reimbursement rates poses significant threats to patient access and provider financial stability, particularly for safety net providers. </p><p>As a result of these factors, 94% of physicians believe it has become more financially and administratively difficult to operate a practice in recent years.<sup>6</sup></p><h2>SETTING THE RECORD STRAIGHT ABOUT PHYSICIAN ACQUISITIONS</h2><p>While a disproportionate amount of attention has been placed on hospitals’ acquisition of physician practices, the reality is that large commercial insurers including CVS Health and UnitedHealth Group have recently spent billions of dollars to acquire physician practices. In fact, non-hospital entities including health insurers have acquired 90% of physician practices over the last five years.<sup>7</sup></p><p>UnitedHealth Group is now the single largest employer of physicians in the country with over 10% of physicians in the U.S. employed or affiliated. We urge this committee to examine the costs and impact on health care access and affordability associated with this widespread acquisition of America’s physicians by corporate health insurance companies.</p><h3>Hospitals and Health Systems Preserve Access to Care</h3><p>Hospitals have offered a lifeline to physician practices struggling to keep their doors open, especially in rural areas. The challenging economics of providing care in rural communities contribute to gaps in access. Rural communities, by nature, generally have fewer people and therefore do not generate the health care utilization to finance the full range of health care services. In addition, caring for rural patients can be more costly on a per patient basis as patients in rural communities tend to have more complex health care needs, are much more likely to be uninsured, and are more likely to rely on public programs when they do have coverage. As such, many providers have struggled to stay open and provide care to their patients and community.</p><p>Hospitals have stepped in to support these access points for rural patients. Despite the fact that hospital have only acquired 6% of all physician practices in the last five years, hospitals were 2.5 times more likely than other entities to acquire practices in rural areas<sup>.8</sup> Commercial insurers in particular are overwhelmingly focused on larger, more profitable markets where the financial upside is greater. Median household income was on average 18.4% higher in counties where insurers acquired physician practices compared to counties where hospitals acquired physician groups.<sup>9</sup> Additionally, the county level population where commercial insurers acquired physician practices was on average 61.4% larger than it was for hospitals.</p><h2>POLICY RECOMMENDATIONS</h2><p>The AHA supports the following policies to address the burdens and costs associated with operating independent physician practices.</p><p><strong>Commercial Insurer Accountability.</strong> Reduce administrative burdens like prior authorization that contribute to provider burnout and delay access to care.</p><ul><li>The AHA supports regulations and legislative solutions that streamline and improve prior authorization processes, including the Improving Seniors’ Timely Access to Care Act, which would codify many of the reforms in the Interoperability and Prior Authorization Final Rule.</li><li>Gold-carding programs substantially reduce administrative burdens and costs by streamlining access to care for Medicare beneficiaries. The AHA supports the GOLD Card Act of 2023 (H.R. 4968), which would exempt providers from requiring prior authorization for a MA plan year if the provider had at least 90% of prior authorization requests approved the preceding year.</li></ul><p><strong>Physician Payment Reform. </strong>Current reimbursement for physicians is woefully inadequate and fails to account for inflation. The AHA supports legislative and regulatory changes to ensure more sustainable physician reimbursement and to facilitate transition to value-based care.</p><ul><li>The current conversion factor updates scheduled in MACRA are insufficient since they are scheduled to begin in 2026 and will only result in a .75% conversion factor update for qualifying advanced Alternative Payment Model (APM) participants and .25% for all other providers. This will exacerbate the widening gap between inflation and physician reimbursement rates. While the one-time conversion factor updates provided in the Consolidated Appropriations Acts of 2022, 2023 and 2024 have provided needed relief in the interim, we encourage more sustainable, real-time approaches to updating the conversion factors in pace with inflation. Annual conversion factor updates should be made to reflect changes in input costs and inflation outside of budget neutrality.</li><li>To support the transition to value-based payment, the AHA urges Congress to extend APM incentive payments and for CMS to remove problematic high/low revenue thresholds that preclude rural and critical access hospitals from obtaining necessary resources for infrastructure investment. We support the Value in Health Care Act (H.R. 5013/S. 3503), which would extend incentive payments, remove revenue distinctions and improve financial benchmarks to ensure participants are not penalized for their own success.</li></ul><p><strong>Provider Well-being.</strong> We urge Congress to continue to address health care worker well-being by supporting the Dr. Lorna Breen Health Care Provider Protection Reauthorization Act (H.R. 7153/S. 3679), which would provide grants to help health care organizations offer behavioral health services to prevent burnout and suicide for health care workers through 2029.</p><h2>CONCLUSION</h2><p>The AHA appreciates your efforts to examine the increased burdens and costs facing physician practices and looks forward to working with you to address these issues.</p><p>__________</p><p><small class="sm"><sup>1</sup> </small><a href="/system/files/media/file/2023/07/The-Majority-of-Nurses-and-Physicians-Say-That-Health-Insurer.pdf"><small class="sm">/system/files/media/file/2023/07/The-Majority-of-Nurses-and-Physicians-Say-That-Health-Insurer.pdf</small></a></p><p><small class="sm"><sup>2</sup> </small><a href="/fact-sheets/2023-06-07-fact-sheet-examining-real-factors-driving-physician-practice-acquisition"><small class="sm">/fact-sheets/2023-06-07-fact-sheet-examining-real-factors-driving-physician-practice-acquisition</small></a></p><p><small class="sm"><sup>3</sup>  </small><a href="https://www.hhs.gov/sites/default/files/health-worker-wellbeing-advisory.pdf"><small class="sm">https://www.hhs.gov/sites/default/files/health-worker-wellbeing-advisory.pdf</small></a></p><p><small class="sm"><sup>4</sup> </small><a href="https://jamanetwork.com/journals/jama/fullarticle/2673148"><small class="sm">https://jamanetwork.com/journals/jama/fullarticle/2673148</small></a></p><p><small class="sm"><sup>5</sup> </small><a class="ck-anchor" href="https://www.ama-assn.org/practice-management/medicare-medicaid/advocacy-action-leading-charge-reform-medicare-pay" id="https://www.ama-assn.org/practice-management/medicare-medicaid/advocacy-action-leading-charge-reform-medicare-pay"><small class="sm">https://www.ama-assn.org/practice-management/medicare-medicaid/advocacy-action-leading-charge-reform-medicare-pay</small></a></p><p><small class="sm"><sup>6 </sup></small><a href="/system/files/media/file/2023/07/The-Majority-of-Nurses-and-Physicians-Say-That-Health-Insurer.pdf"><small class="sm">/system/files/media/file/2023/07/The-Majority-of-Nurses-and-Physicians-Say-That-Health-Insurer.pdf</small></a></p><p><small class="sm"><sup>7</sup> </small><a href="/system/files/media/file/2023/06/Private-Equity-and-Health-Insurers-Acquire-More-Physicians-than-Hospitals-Infographic.pdf"><small class="sm">/system/files/media/file/2023/06/Private-Equity-and-Health-Insurers-Acquire-More-Physicians-than-Hospitals-Infographic.pdf</small></a></p><p><small class="sm"><sup>8 </sup>AHA analysis of Levin Associates data on physician medical groups between 2019 and 2023.</small></p><p><small class="sm"><sup>9 </sup> Ibid.</small></p> Wed, 22 May 2024 15:36:09 -0500 Testimony