DCMedical News: January 10, 2018
DCMedical News
Washington, D.C.
Wednesday, January 10, 2018
THE BIG STORY TODAY IN HEALTH CARE
HOSPITALS and HEALTH FACILITIES
Neighborhood health centers were created in 1966, a “Great Society” safety net program. Later consolidated under Section 330 of the Public Health Service Act (42 U.S.C. §254b), the centers became the nucleus of the Federally Qualified Health Centers (FQHCs), promising comprehensive, community-based care. The centers were expanded dramatically under Bush ’43, a border state Governor. For underserved economic groups, including many immigrants, the FQHCs became the doctor-health plan-nurse practitioner-dentist all in one, the clinic. We have more than 10,000 of them now, critical in urban areas (especially in safety net and metropolitan centers of immigration) and rural (often the only organized health system) alike. (See the National Association of Community Health Centers, “Community Health Center Chartbook,” or a nice Commonwealth Fund summary piece, “Care for Millions at Risk as Community Health Centers Lose Billions in Funding,” 12-21-2017, found here.) Commonwealth estimates that, without renewal of authorization and continued federal funding, nine million people, one-third of the community health center patients, will lose access to their clinics. They join the nine million children covered under CHIP, legislative authorization extended to the end of March, uncertain thereafter.
HEALTH INSURANCE, MEDICARE, MEDICAID, COMMERCIAL
HHS and (reportedly) White House staff have circulated a discussion paper, undated, found here, articulating a philosophy of promoting competition and reducing regulatory burden, consistent with Executive Order 13813 (found here), discussing the relationship of Association Health Plans (AHPs), Short-Term, Limited-Duration Insurance (STLDI) and Health Reimbursement Arrangements (HRAs) to these competition goals. The discussion paper solicits (it is labeled a “Request for Information”) input from the public on the extent to which regulation inhibits choice, and how the state (!) and federal governments might respond. Resources to assist in commenting can be found at https://aspe.hhs.gov/pdfreport/ competition‐rfi. Comments will be received through January 25, 2018. HHS has reportedly not decided whether or not to share the comments, but there will undoubtedly be a lot of them. Take a chance, fire away!
More on AHPs. We reported the standard items (edition of January 8, here) based on the January 5 proposed rule (here). The rule, however, is all of two pages long (here), the remaining 21 pages in the Federal Register publication a fascinating discussion (some repetition, no doubt multiple authors) of the American health insurance market, based on reports to the Department of Labor (DoL). That Department is guardian of, among other statutes, the Employee Retirement Income Security Act (ERISA) of 1974, the beginning of self-insurance by large (more than 50 employees now) companies. ERISA plans escape state mandates, such as the “mandated” coverage of providers not ordinarily included in health plans, but also avoid the PPACA responsibilities which sought to protect the individual and small group plans, namely Essential Health Benefits; risk adjustment (transferring funds from plans with lower-risk enrollees to plans with higher-risk enrollees, see Dowling, M., Northwell exit); the risk pool adjustment; and premium rules that prohibit issuers from varying premiums except with respect to location, limited age brackets, family size and (some) tobacco use; and the Medical Loss Ratio requirements (80% for smaller groups, 85% for large group plans). The thrust of the discussion (in this proposed rule) is that AHPs, rather than eroding protections (pre-existent conditions), are intended to give the unrelated, the unincorporated and the unrepresented (by insurers) the same health plan advantages that are available to self-insured plans or that are underwritten for large groups. Considerable discussion takes place (in these pages) concerning the potential for AHPs to become large enough to successfully bargain with providers, and even to compete with major insurers, to wit: “This proposed rule aims to encourage the establishment and growth of AHPs comprising otherwise unrelated small businesses, including working owners, and to clarify that nationwide industry organizations such as trade associations can sponsor nationwide AHPs (emphasis added, pg. 626). In any event, worth a read.
EVENTS & PUBLICATIONS, MEETINGS AND READINGS
Your January Calendar:
January 11: Kaiser Family Foundation, on Health Reform 2020, 8:30 to 3:00, 1330 G St., N.W., Washington, D.C.
January 11: MedPAC, continuing to Friday, January 12 (agenda here)
January 17: Reinventing Rural Health, BiPartisan Policy Center, 1225 Eye Street, Washington, D.C.
January 25: MACPAC, 1800 M. Street, Suite 650, Washington, D.C., and continuing to Friday, January 26
January 29: COGME, Bethesda, MD, Livestream at https://hrsa.connectsolutions.com/cogme-council/, also January 30
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Notes to: Fred Hyde, MD, JD, MBA; fredhyde@aol.com