/ en Thu, 22 May 2025 16:26:56 -0500 Fri, 11 Apr 25 12:10:58 -0500 /lettercomment/2025-04-11-aha-comments-cms-marketplace-integrity-and-affordability-rule <p>April 11, 2025</p><p>Mehmet Oz, M.D.<br>Administrator<br>Centers for Medicare & Medicaid Services<br>Hubert H. Humphrey Building<br>200 Independence Avenue, S.W., Room 445-G<br>Washington, DC 20201</p><p><em><strong>RE: Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability (CMS-9884-P)</strong></em></p><p>Dear Administrator Oz:</p><p>On behalf of the 黑料正能量 Association鈥檚 (AHA) nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 90 that offer health plans, and our clinician partners 鈥� including more than 270,000 affiliated physicians, 2 million nurses and other caregivers 鈥� and the 43,000 health care leaders who belong to our professional membership groups, we thank you for the opportunity to respond to the Centers for Medicare & Medicaid Services (CMS) rule on marketplace integrity and affordability.</p><p><strong>We appreciate CMS鈥� attention to concerns regarding the inappropriate enrollment of large numbers of low-income individuals into Health Insurance Marketplace coverage by certain brokers. </strong>As detailed in the proposed rule, it appears that in several states, some brokers have enrolled cohorts of low-income individuals (including, at times, Medicaid enrollees) into marketplace plans without the individuals鈥� knowledge. This has led to patient confusion, barriers to care and financial pressure on hospitals.</p><p>These impacts have been confirmed by AHA member hospitals. In these instances, hospitals scheduled services for patients when their coverage indicated Medicaid. In one example, the hospital only learned that the patient鈥檚 coverage had changed upon submitting the bills for care to the appropriate Medicaid agency, which then denied the claims due to the patient having marketplace coverage. The patients were completely unaware of this change in their coverage, and, unfortunately, in many instances, the hospital was not in-network with the marketplace plan, leaving the care uncovered. This change in coverage without the patients鈥� consent is interfering with patients' access to care, including services being postponed or canceled. One health system shared that they have found 2,500 unique patients with this issue, resulting in over $45 million in outstanding claims going unpaid as a result. A separate health care system estimates the financial impact on their hospitals is much greater.</p><p>The agency has proposed several policy changes to address this issue. While we appreciate the agency taking action to stop these inappropriate enrollments, we are concerned that the proposed changes will create barriers for truly eligible marketplace consumers without sufficient focus on the agents and brokers instigating these enrollments. <strong>Taken with other policies in the rule, CMS estimates that between 750,000 to 2 million consumers could lose their coverage.</strong> We are deeply concerned by these estimates of coverage loss, particularly as we have seen no credible evidence to support that such a high number of individuals have been impacted by inappropriate broker enrollments.</p><p><strong>Coverage loss of this magnitude would have substantial consequences for patient access to care, as well as the financial stability of hospitals, health systems, and other providers.</strong> As CMS notes in the rule, 鈥渟ome enrollees, particularly those facing financial constraints, might need to adjust their household budgeting to maintain coverage or, if they are not able to, become uninsured. Depending on the circumstances, these enrollees, if they become uninsured, could face higher costs for care and medical debt if care is needed. <em>These costs could in turn be incurred by hospitals and municipalities in the form of uncompensated care</em>鈥� (emphasis added). These new costs to hospitals would come at a time when many hospitals and health systems, particularly critical access hospitals and those in rural areas, are operating with little to no margin. They cannot absorb further losses without consequences on access to care that will be felt by everyone in a community, not just those enrolled in marketplace coverage.<sup>1</sup></p><p><strong>For these reasons, we encourage the agency to pause finalizing many of these policies to give it and stakeholders additional time to consider the impacts while simultaneously investigating and taking appropriate action to stop the specific agents and brokers responsible for these inappropriate enrollments. In addition, we urge the agency to address reimbursement for services rendered to those impacted patients.</strong></p><p>Thank you for your consideration, and we look forward to working with the administration to ensure efficient and affordable marketplaces.<strong> </strong>Please contact me if you have questions, or feel free to have a member of your team contact Ariel Levin, AHA鈥檚 director of coverage policy, at 202-626-2335 or <a href="mailto:alevin@aha.org">alevin@aha.org</a>.</p><p>Sincerely,</p><p>/s/</p><p>Ashley Thompson<br>Senior Vice President<br>Public Policy Analysis and Development</p><div><hr><div id="ftn1"><p><sup>1</sup> <a href="/costsofcaring">/costsofcaring</a></p></div></div> Fri, 11 Apr 2025 12:10:58 -0500 Making Healthcare More Affordable <div class="container"><div class="row"><div class="col-md-8"><p>The Centers for Medicare & Medicaid Services (CMS) March 10 <a href="https://www.cms.gov/files/document/MarketplacePIRule2025.pdf" target="_blank" title="CMS: Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability">released new proposed policies</a> for health insurance marketplaces, including the issuers, agents and brokers who assist marketplace enrollees. If finalized, the rule would shorten the open enrollment period for all marketplaces to Nov. 1-Dec. 15 and address issues with brokers fraudulently enrolling individuals without their consent by ending a special enrollment period (SEP) for low-income individuals. CMS also proposes a change to the premium adjustment percentage that would increase the maximum annual cost sharing limitation. The proposed rule includes updates to the income verification process and pre-enrollment verification process for SEPs, changes to the essential health benefits, and modifications to the redetermination and re-enrollment processes, among other policies. Many of the proposed policies would reinstate policies previously finalized during the prior Trump administration.</p><h2>Major Provisions</h2><h3>Open Enrollment</h3><p>CMS proposes to shorten the open enrollment period to Nov. 1-Dec. 15 for all individual market coverage, on and off the marketplaces and including those marketplaces operated by individual states, beginning in 2025 for the 2026 coverage year. Currently, open enrollment periods for federally facilitated marketplaces run from Nov. 1-Jan. 15; state-based marketplaces (SBM) have flexibility to extend open enrollment beyond that window.</p><h3>Low-income Monthly SEP</h3><p>CMS proposes to end the monthly SEP for those with projected household incomes at or below 150% of the federal poverty level (FPL). This proposal is expected to help curtail ongoing broker fraud in which brokers enroll individuals in marketplace plans without their knowledge or authorization.</p><h3>Agent, Broker and Web-broker Termination</h3><p>CMS proposes to improve transparency of agent, broker and web-broker compliance review by adopting a 鈥減reponderance of the evidence" standard. CMS expects this to reduce noncompliant behavior, including improper and unauthorized enrollment.</p><h3>Premium Adjustment Percentage Methodology</h3><p>CMS proposes to revert to the premium adjustment percentage methodology finalized in the 2020 Notice of Benefit and Payment Parameter, which uses private health insurance premiums to estimate the future premium growth. This calculation is used to determine cost-sharing parameters, such as the maximum annual limitation on cost sharing.</p><p>Based on the proposed methodology, CMS proposes a maximum annual limitation on cost sharing for plan year 2026 of $10,600 for self-only coverage and $21,200 for family coverage. These amounts are roughly 15 percent higher than the plan year 2025 cost-sharing limits.</p><h3>Eligibility Verification for SEP</h3><p>CMS proposes to require pre-enrollment eligibility verification for all types of SEPs across all marketplaces, including SBMs. Currently, pre-enrollment verification is limited to the loss of minimum essential coverage SEP. In addition, CMS proposes to require all marketplaces to conduct pre-enrollment eligibility verification for at least 75 percent of all new enrollees.</p><h3>De Minimis Thresholds</h3><p>CMS proposes to widen the de minimis ranges for most individual and small group market plans subject to the actuarial value requirements to +2/-4 percentage points. For expanded bronze plans, CMS proposes a new de minimis range of +5/-4 percentage points. CMS also proposes to remove the de minimis range requirements of +2/0 percentage points for individual market silver plans, as well as the +1/-1 percentage point de minimis range for silver cost-sharing reduction plans.</p><h3>Deferred Action for Childhood Arrivals (DACA) Recipients</h3><p>CMS proposes to change the definition of 鈥渓awfully present鈥� so that DACA recipients would no longer be eligible to enroll in marketplace or basic health plans or receive premium tax credits or cost-sharing reductions. DACA recipients recently gained eligibility through the 2024 DACA Rule.</p><h3>Essential Health Benefits</h3><p>CMS proposes prohibiting classifying gender-affirming care as an essential health benefit beginning in plan year 2026. Plans could cover gender-affirming care if they choose to.</p><h3>Program Integrity</h3><p>CMS proposes several policies intended to ensure that individuals are only enrolling in plans and receiving premium tax credits that they are eligible to receive, including:</p><ul><li>Requiring all enrollees who attest to projected household income between 100-400% FPL but whose income verification results in a household income below 100% FPL to answer additional verification questions and provide supporting documentation. This policy is intended to ensure only eligible individuals above 100% FPL receive premium tax credits. This policy was finalized in the 2019 Notice of Benefit and Payment Parameters but was vacated by the courts.</li><li>Reinstating a policy deeming an individual ineligible for future premium tax credits if they fail to file their federal income tax and reconcile premium tax credits for one year. This policy was changed to two consecutive tax years in the 2024 Notice of Benefit and Payment Parameters.</li><li>Requiring marketplaces to verify income with other trusted data sources if IRS data is not available, including requiring additional supporting documentation or other actions by enrollees. Currently, marketplaces must accept enrollees鈥� self-attestation of projected household income if IRS income verification is not possible.</li><li>Removing the 60-day extension of the statutorily required 90-day window during which enrollees must resolve income inconsistencies.</li></ul><h3>Additional Policies</h3><p>CMS proposes several additional policies, including:</p><ul><li>Allowing issuers to require that enrollees pay past-due premiums before enrolling in new coverage.</li><li>Eliminating the fixed-dollar and gross percentage-based premium thresholds finalized in the 2026 Notice of Benefit and Payment Parameters and requiring issuers to adopt a net percentage-based threshold, which would require enrollees to pay more of their premium to maintain coverage.</li><li>Changing the eligibility redetermination process for enrollees in zero-dollar premium plans to require enrollees to affirm or update their eligibility information or face $5 premiums upon re-enrollment. The premiums would be eliminated once the enrollee confirmed their eligibility.</li><li>Remove the re-enrollment hierarchy that allows marketplaces to re-enroll low-income bronze plan enrollees into a silver plan, if the silver plan is the same product, has the same provider network and has an equal or lower premium.</li></ul><h3>Coverage Impacts</h3><p>CMS estimates that between 750,000 and 2 million individuals would lose marketplace coverage in 2026 as a result of the policies proposed in this rule. Some of that coverage loss would be due to improper and unauthorized enrollment by agents and brokers, while other losses would be due to the increased administrative burden associated with complying with the new requirements.</p><h2>Further Questions</h2><p>Comments on the proposed rule are due 30 days following publication in the Federal Register. For more information, contact Ariel Levin, AHA鈥檚 director of coverage policy, at <a href="mailto:alevin@aha.org?subject=RE: Regulatory Advisory: CMS Issues 2025 Marketplace Integrity and Affordability Proposed Rule">alevin@aha.org</a>.</p></div><div class="col-md-4"><a href="/system/files/media/file/2025/03/Regulatory-Advisory-CMS-Issues-2025-Marketplace-Integrity-and-Affordability-Proposed-Rule.pdf"><img src="/sites/default/files/inline-images/Page-1-Regulatory-Advisory-CMS-Issues-2025-Marketplace-Integrity-and-Affordability-Proposed-Rule.png" data-entity-uuid="cd05876f-3ced-4647-9ea0-5a72630acf19" data-entity-type="file" alt="Regulatory Advisory: CMS Issues 2025 Marketplace Integrity and Affordability Proposed Rule page 1." width="695" height="900"></a></div></div></div> Tue, 11 Mar 2025 16:39:48 -0500 Making Healthcare More Affordable /advocacy-agenda <div class="raw-html-embed"><div class="container"> <div class="row"> <div class="col-md-8"> <h2><span>Introduction</span></h2> <p>America鈥檚 hospitals and health systems are unwavering in their commitment to delivering safe and quality care to every patient, in every community. The blue and white 鈥淗鈥� symbol is a beacon of healing, hope and health in every community nationwide.</p> <p>Despite this steadfast commitment, hospitals and health systems face formidable challenges. They continue to grapple with significant workforce shortages, escalating costs of care, inadequate government reimbursement and a heavy regulatory burden.</p> <p>In 2025, the 黑料正能量 Association (AHA) will engage with Congress, the Administration, regulatory bodies and the judiciary to shape public policy to advance hospitals鈥� efforts to provide quality patient care. The AHA also will focus on ensuring the long-term viability of hospitals to serve their communities and promote health and wellness.</p> <p>By addressing these challenges head-on, the AHA supports hospitals and health systems in their crucial role of caring for patients and advancing health, ensuring that the promise of the 鈥淗鈥� symbol remains strong and reliable.</p> <p>Our 2025 Advocacy Agenda is focused on:</p> <ul class="diamond"> <li class="diamond"><strong>Ensuring Access to Care</strong></li> <li class="diamond"><strong>Strengthening the Health Care Workforce</strong></li> <li class="diamond"><strong>Advancing Quality and Health Care System Resiliency</strong></li> <li class="diamond"><strong>Leading Innovation in Care Delivery</strong></li> <li class="diamond"><strong>Reducing Health Care System Costs for Patient Care</strong></li> </ul> <p>The following includes a detailed list of our advocacy priorities and key highlights. Please explore this page and the Advocacy link in our website navigation for more resources and information on the priorities in this document and our latest advocacy campaigns.</p> </div> <div class="col-md-4"> <div class="external-link spacer"><strong><strong><a class="btn btn-wide btn-primary" href="/system/files/media/file/2025/01/AHA-2025-Advocacy-Agenda-20250114.pdf" target="_blank" title="Click here to download the AHA 2025 Advocacy Agenda PDF.">Download the 2025 Advocacy Agenda PDF</a></strong></strong></div> <p><a href="/system/files/media/file/2025/01/AHA-2025-Advocacy-Agenda-20250114.pdf" target="_blank" title="Click here to download the AHA 2025 Advocacy Agenda PDF."><img alt="黑料正能量 Association 2025 Advocacy Agenda cover." src="/sites/default/files/2025-01/Page-1-AHA-2025-Advocacy-Agenda-20250114.png"></a></p> </div> </div> </div> <div class="container"> <h2><span>Detailed Advocacy Agenda</span></h2> <div class="col-md-12 cc_tabs"> /* reset */ .cc_tabs ul.a-container { 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transparent; border-right: 6px solid transparent; border-bottom: 8px solid #fff; border-left: 6px solid transparent; top: 6px; } .cc_tabs .a-content { padding: 0 20px 20px; display: none; height:auto; max-height: 40vh; overflow: auto } .cc_tabs .a-container input:checked ~ .a-content { display: block; } /* Style the tab */ .cc_tabs .tab { background-color: #fff; width: auto; height: auto; overflow: auto; } /* Style the buttons inside the tab */ .cc_tabs .tab button { display: block; background-color: lightgry; color: #003087; padding: 10px 16px 10px 20px; width: calc(16% - 30px); height: 150px; /*added by Nia 1/23/25 to align tab heights*/ border: solid 1px lightgray; outline: none; text-align: center; cursor: pointer; transition: 0.3s; font-size: 15px; float: left; /*overflow: auto; Hidden to prevent scroll in tab title */ margin: 0px 15px; -webkit-border-top-left-radius: 15px; -webkit-border-top-right-radius: 15px; -moz-border-radius-topleft: 15px; -moz-border-radius-topright: 15px; border-top-left-radius: 15px; border-top-right-radius: 15px; font-weight: 700; } @media (max-width:452px){ .cc_tabs .tab button{ padding: 10px 5px 10px 5px; width: calc(50% - 4px); font-size: 17px; margin: 0px 2px; } } /* Change background color of buttons on hover */ .cc_tabs .tab button:hover { background-color: #003087; color:#fff } /* Create an active/current "tab button" class */ .cc_tabs .tab button.active { background-color: #003087; color: #ffffff } /* Style the tab content */ .cc_tabs .tab .tabcontent { float: left; padding: 15px 12px; border: 1px solid #ccc; width: 100%; height: auto; } .cc_tabs .tablinks:after { content: '\2610'; color: #777; font-weight: bold; float: right; margin-left: 5px; } .cc_tabs .tablinks.active:after { content: "\2611"; } <div class="tab">Key HighlightsEnsuring Access to CareStrengthening the Health Care WorkforceAdvancing Quality and Health Care System ResiliencyLeading Innovation in Care DeliveryReducing Health Care System Costs for Patient Care</div> <div class="tabcontent" id="highlights"> <ul class="a-container"> <li class="a-items"> Highlights <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Extend the Enhanced Premium Tax Credits</strong> to ensure millions of Americans can continue to access health insurance and prevent hospitals from shouldering an even greater financial burden.</li> <li class="diamond">Ensure essential health care services are available in all communities by <strong>safeguarding federal funding for Medicare, Medicaid, the Children鈥檚 Health Insurance Program and the Health Insurance Marketplaces.</strong></li> <li class="diamond"><strong>Reject additional payment cuts</strong> that do not recognize legitimate differences among provider settings (<strong>so-called site-neutral or facility-fee payment policies</strong>).</li> <li class="diamond"><strong>Protect the 340B Drug Pricing Program</strong> to ensure hospitals can maintain vital patient services and expand access to care.</li> <li class="diamond"><strong>Ensure Medicaid is fully funded</strong> to allow hospitals to continue to serve the Medicaid, uninsured and marginalized populations in their communities, including through support of the current FMAP rates, the Medicaid Disproportionate Share Hospital program, Upper Payment Limits and Directed Payments, and the financing sources that sustain them.</li> <li class="diamond">Bolster support for hospitals and health systems so they can <strong>prepare for and respond to natural and man-made disruptions, including natural disasters, cyberattacks and supply chain failures.</strong></li> <li class="diamond"><strong>Hold commercial health insurers accountable</strong> for ensuring appropriate patient access to care, including reducing the excessive use of utilization management programs, ensuring adequate provider networks, reducing account receivables and limiting inappropriate denials for services.</li> <li class="diamond"><strong>Bolster the health care workforce</strong> by enacting important protections against violence in health care settings, eliminating federal restrictions that limit the ability of providers to practice at the top of their license, and increasing funding for clinical training programs.</li> <li class="diamond"><strong>Enact regulatory and administrative relief</strong> from burdensome policies that take caregivers away from providing patient care and increase costs for patients and the health care system.</li> </ul> </div> </li> </ul> </div> <div class="tabcontent" id="accesstocare"> <ul class="a-container"> <li class="a-items"> Financial Stability of the Health Care System <div class="a-content"> <ul class="diamond"> <li class="diamond">Ensure essential health care services are available in all communities by <strong>safeguarding federal funding for Medicare, Medicaid, the Children鈥檚 Health Insurance Program and the Health Insurance Marketplaces.</strong> Government programs currently reimburse providers significantly less than the cost of delivering care.</li> <li class="diamond">Ensure patient access to critical care and other outpatient services by <strong>rejecting additional payment cuts</strong> that do not recognize legitimate differences among provider settings (also known as so-called site-neutral or facility-fee payment policies) and policies that restrict patient access to certain sites of care (also known as site-of-service policies).</li> <li class="diamond">Preserve the gains in health coverage made over the past decade, including by <strong>extending the Enhanced Premium Tax Credits</strong> for coverage through the health insurance marketplaces.</li> <li class="diamond"><strong>Protect the 340B Drug Pricing Program</strong> to ensure hospitals can maintain vital patient services and expand access to care by reversing harmful policies and holding drug manufacturers accountable to the program rules, <strong>especially community pharmacy arrangements.</strong></li> <li class="diamond"><strong>Ensure Medicaid is fully funded</strong> to allow hospitals to continue to serve the Medicaid, uninsured and underserved populations in their communities, including through support of the current FMAP rates, the Medicaid Disproportionate Share Hospital program, Upper Payment Limits and Directed Payments, and the financing sources that sustain them.</li> <li class="diamond">Pursue a new <strong>鈥渕etropolitan anchor hospital鈥�</strong> designation for certain hospitals that provide critical health care services to marginalized and underrepresented communities.</li> <li class="diamond">Ensure the <strong>Federal Emergency Management Agency follows through on its commitment to reimburse hospitals</strong> appropriately and timely for the resources they provide during public health emergencies and other disasters.</li> <li class="diamond"><strong>Mitigate Medicare payment reductions to ensure patient access to physicians.</strong></li> <li class="diamond"><strong>Rein in rising drug costs</strong> by taking steps to increase drug manufacturer competition, improve drug pricing transparency and hold pharmacy benefit managers accountable for illegal practices that increase costs and reduce coverage for patients and providers.</li> <li class="diamond"><strong>Enact regulatory and administrative relief</strong> from burdensome policies that take caregivers away from providing patient care and increase costs for patients and the health care system.</li> <li class="diamond"><strong>Protect not-for-profit hospitals鈥� tax-exempt</strong> status so they can continue providing community benefits tailored to their communities鈥� unique needs, demographics and policy realities.</li> <li class="diamond"><strong>Protect access to clinical laboratory services in hospital-based laboratories.</strong></li> <li class="diamond">Protect access to care by <strong>preserving the existing ban on the growth and expansion of physician-owned hospitals.</strong></li> </ul> </div> </li> <li class="a-items"> Coverage and Access <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Ensure access to care for veterans</strong> by working with the Department of Veterans Affairs as it implements the next generation of comprehensive community care for veterans.</li> <li class="diamond">Support policy and federal oversight changes to <strong>ensure the appropriate use of donated organs in time for a successful transplant</strong>, the ability to effectively use new strategies for harvesting and preserving organs until donated and coordinated, and rational regulation of transplant centers, donor hospitals and organ procurement organizations.</li> </ul> </div> </li> <li class="a-items"> Rural Hospitals <div class="a-content"> <ul class="diamond"> <li class="diamond">Protect rural communities鈥� access to care by <strong>making permanent critical programs, including the Medicare-dependent Hospital designation, Low-volume Adjustment and ambulance add-on payment.</strong></li> <li class="diamond">Improve rural health programs by <strong>reopening the necessary provider designation for Critical Access Hospitals (CAHs), reversing cuts to Rural Health Clinic payments, removing the 96-hour condition of payment for CAHs and further strengthening Medicare-dependent and Sole Community Hospitals</strong> by allowing participating hospitals to choose from an additional base year when calculating payments.</li> <li class="diamond">Advance rural health care alternatives to ensure care delivery and financing by <strong>supporting and refining the Rural Emergency Hospital model.</strong></li> <li class="diamond">Continue to support legislation that would <strong>place a floor on the area wage index, effectively raising it for hospitals below that threshold with new money.</strong></li> <li class="diamond"><strong>Support Medicare Advantage payment parity for CAHs</strong> to ensure the long-term health of providers and facilities that care for patients in rural areas, considering the volume of Medicare Advantage enrollment in those communities.</li> </ul> </div> </li> <li class="a-items"> Post-Acute Care <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Bolster patient access to post-acute care by establishing appropriate network adequacy requirements</strong> for long-term care hospitals, inpatient rehabilitation facilities, skilled nursing facilities and home health agencies.</li> <li class="diamond"><strong>Eliminate the proposed minimum staffing requirements for skilled nursing and long-term care facilities</strong> and instead press for long-term solutions to health care workforce shortages.</li> <li class="diamond"><strong>Provide stability under the long-term care hospital prospective payment system</strong> through legislative and regulatory reforms that provide adequate reimbursement for high-cost patients and those with high acuity levels.</li> <li class="diamond"><strong>Ensure Medicare Advantage beneficiaries have access to the same post-acute care benefits as Traditional Medicare beneficiaries</strong> by holding plans accountable through robust oversight and enforcement.</li> <li class="diamond">Reduce administrative burden for post-acute care providers by <strong>eliminating unnecessary data reporting requirements.</strong></li> </ul> </div> </li> <li class="a-items"> Behavioral Health <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Implement policies to better integrate and coordinate behavioral health services with physical health services</strong>, including developing alternative payment models and bundled payments that incorporate behavioral and physical health services and financially supporting the implementation of team-based care models.</li> <li class="diamond"><strong>Eliminate Medicare鈥檚 90-day lifetime limit for inpatient psychiatric admissions.</strong></li> <li class="diamond"><strong>Repeal the Medicaid Institutions for Mental Disease exclusion</strong>, which prohibits the use of federal Medicaid funds to cover inpatient mental health services for patients aged 21 to 64 in certain freestanding psychiatric facilities.</li> <li class="diamond"><strong>Reauthorize key programs in the SUPPORT for Patients and Communities Act</strong>, which would extend expiring payments, grants and other programs for substance use disorder treatment and prevention.</li> <li class="diamond"><strong>Increase targeted funding for facilities that provide specialty mental health services</strong> (including pediatric, geriatric and multi-substance use disorders) and <strong>invest in the behavioral health workforce</strong> by creating dedicated Medicare-funded graduate medical education slots for these specialties.</li> <li class="diamond"><strong>Make permanent the Certified Community Behavioral Health Center demonstration program.</strong></li> <li class="diamond"><strong>Eliminate or amend outdated and unnecessary Conditions of Participation for psychiatric facilities</strong> related to emergency care and treatment planning documentation.</li> <li class="diamond">Strengthen enforcement through significant <strong>penalties for health plans that violate the Mental Health Parity and Addiction Equity Act and subsequent rules.</strong></li> </ul> </div> </li> <li class="a-items"> Commercial Insurer Accountability <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Hold commercial health insurers accountable for ensuring appropriate patient access to care</strong>, including by reducing the excessive use of prior authorization, ensuring adequate provider networks, limiting inappropriate denials for services that should be covered and prohibiting certain specialty pharmacy policies, like insurer-mandated 鈥渨hite bagging,鈥� that create patient safety risks and limit patient access to certain medications in hospital settings.</li> <li class="diamond"><strong>Ensure stronger enforcement of federal rules related to Medicare Advantage</strong> through increased oversight and insurer scrutiny.</li> <li class="diamond"><strong>Increase oversight and accountability of commercial health plans through increased data collection, reporting and transparency</strong> on core plan performance metrics that are meaningful indicators of patient access, such as appeals, denials and grievances, and reporting on using algorithms and artificial intelligence in utilization management programs.</li> <li class="diamond"><strong>Establish a prompt payment standard for Medicare Advantage</strong> to ensure timely claims payment.</li> <li class="diamond"><strong>Apply guardrails to insurer algorithms and artificial intelligence use</strong> to ensure these tools do not inappropriately create barriers for patients to access medical care.</li> <li class="diamond">Ensure patients can rely on their coverage by <strong>disallowing health plans from inappropriately delaying and denying care</strong>, including by making unilateral mid-year coverage changes.</li> <li class="diamond"><strong>Prevent improper insurer manipulation of oversight tools</strong> designed to ensure premium dollars are spent on patient care (e.g., medical loss ratio requirements).</li> <li class="diamond">Advocate for regulatory and legislative solutions to <strong>prevent health plans from enacting inappropriate fees for electronic payments.</strong></li> </ul> </div> </li> </ul> </div> <div class="tabcontent" id="workforce"> <ul class="a-container"> <li class="a-items"> Workforce Shortages <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Address physician shortages</strong>, including shortages of behavioral health providers, by increasing the number of residency slots eligible for Medicare funding while rejecting cuts to Medicare graduate medical education.</li> <li class="diamond">Encourage the <strong>continuation of visa waivers for physicians in medically underserved areas and recapture of unused employment visas for doctors and nurses.</strong></li> <li class="diamond">Address nursing shortages by <strong>reauthorizing nursing workforce development programs</strong> to support recruitment, retention and advanced education for nurses and other allied health professionals and investing in nursing schools, nurse faculty salaries and hospital training time.</li> <li class="diamond"><strong>Reduce administrative burdens that take clinicians away from the bedside and contribute to burnout</strong>, such as excessive and unnecessary prior authorization use and inappropriate coverage denials that require substantive clerical rework by staff.</li> <li class="diamond"><strong>Support apprenticeship programs for nursing assistants and other critical support staff positions.</strong></li> <li class="diamond"><strong>Adopt policies to expand loan repayment and other incentive-based programs to retain existing talent and attract new talent</strong>, including through continued funding of the National Health Service Corps and National Nurse Corps.</li> </ul> </div> </li> <li class="a-items"> Workforce Safety <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Strengthen workplace safety by enacting federal protections for health care workers against violence and intimidation</strong> and providing hospitals with grant funding for education and training programs, coordination efforts with state and local law enforcement, and physical plant improvements.</li> <li class="diamond"><strong>Reject additional federal workplace violence regulations that would be duplicative of the rigorous accreditation requirements hospitals already face</strong> and that would add administrative burden.</li> <li class="diamond">Protect health care workers from threats against them in their homes by <strong>permanently removing the requirement that practitioners rendering telehealth services from their homes report their home addresses on Medicare enrollment or claims forms.</strong></li> </ul> </div> </li> <li class="a-items"> Licensure Standards <div class="a-content"> <ul class="diamond"> <li class="diamond">Support efforts to <strong>allow non-physicians to practice at the top of their licenses.</strong></li> <li class="diamond">Allow non-physician licensed practitioners to provide and be paid for certain clinical services, including behavioral health services, by <strong>expediting licensure processes, allowing for general rather than direct supervision and removing unnecessary practice restrictions as clinically appropriate.</strong></li> <li class="diamond"><strong>Promote medical licensure reciprocity to allow practitioners to work across state lines.</strong></li> <li class="diamond"><strong>Remove unnecessary and stigmatizing language around mental health from licensure and credentialing processes.</strong></li> </ul> </div> </li> </ul> </div> <div class="tabcontent" id="quality"> <ul class="a-container"> <li class="a-items"> Quality <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Advocate for streamlined Conditions of Participation</strong> and other regulatory standards that promote safe, high-quality care without increasing administrative burden.</li> <li class="diamond">Pursue strategies and support public policies aimed at <strong>improving maternal and child health access and outcomes.</strong></li> <li class="diamond"><strong>Enhance the effectiveness and lower the burden of the Physician Quality Payment Program</strong> by advocating for more accurate and meaningful cost measures and appropriately pacing the implementation of new program approaches, such as the Merit-based Incentive Payment System Value Pathways.</li> <li class="diamond">Promote approaches to <strong>account for health-related social needs in quality measurement and value programs where appropriate</strong> to ensure appropriate performance comparisons and payment adjustments.</li> <li class="diamond"><strong>Advocate for measures that matter in advancing quality and patient safety</strong> and that help hospitals and health systems identify important opportunities to ensure all patients achieve the best possible outcomes for their conditions. Work to ensure federal, state, and payer performance assessments use these same measures in order to reduce measurement burden.</li> <li class="diamond"><strong>Advocate to discontinue measures</strong> that either fail to provide meaningful, credible information to advance patient quality or safety or have administrative burdens that outweigh their value to improving care.</li> <li class="diamond"><strong>Promote meaningful changes</strong> in federal funding of research to improve the delivery of safe, effective care, the efficiency of care, the effective use of care teams, and the leadership and governance processes most likely to yield improvements in patient outcomes and experience of care.</li> </ul> </div> </li> <li class="a-items"> Resiliency and Preparedness <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Advocate for increased annual appropriations for the Hospital Preparedness Program</strong> to ensure that the health care infrastructure is ready to respond to crises. Continue efforts to ensure that most of this funding is awarded to hospitals and health systems to enhance emergency preparedness and surge capacity.</li> <li class="diamond">Support federal incentives and investments to improve <strong>hospitals鈥� disaster preparedness and operational resiliency.</strong></li> <li class="diamond">Prevent and address shortages of critical medical drugs, devices, blood and blood products, and supplies, including working with Congress and the federal government to bring about policy changes that will <strong>avert future shortages by strengthening the medical supply chain.</strong></li> <li class="diamond"><strong>Advance policies that assist in protecting health care services, data and patients from cyberattacks</strong> while supporting efforts to deliver broader gains in computer security by shifting the burden of cybersecurity away from individual health systems.</li> <li class="diamond"><strong>Continue to support federal incentives and investments to improve the security posture of hospitals and health systems</strong>, including regulatory relief for hospitals and health systems that suffer a cyberattack despite having recognized cybersecurity practices in place, and push back on any new cybersecurity regulation not inclusive of the entire health sector.</li> <li class="diamond"><strong>Advocate for increased accountability of third-party technology vendors in HIPAA.</strong></li> <li class="diamond"><strong>Support regulation of artificial intelligence that enables continued innovation while providing reasonable guardrails</strong> to ensure patient safety and improved outcomes for all patients.</li> <li class="diamond"><strong>Support clear minimum privacy standards in HIPAA</strong> that account for how data is used, shared and created in hospitals and health systems.</li> <li class="diamond"><strong>Support the continued development of clinician burden reduction technologies</strong> to help caregivers reduce administrative requirements to spend more time on direct patient care.</li> <li class="diamond">Advocate for the adoption of a <strong>universal patient identification number</strong> to support patient safety efforts.</li> <li class="diamond">Continue to support federal investments in <strong>improving broadband infrastructure</strong>, especially in rural and underserved areas of the country.</li> </ul> </div> </li> </ul> </div> <div class="tabcontent" id="innovation"> <ul class="a-container"> <li class="a-items"> Leading Innovation in Care Delivery <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Support the move to value-based care</strong>, with a particular focus on solutions for the longterm financial viability of hospitals and health systems by offering some level of predictable, up-front payment.</li> <li class="diamond"><strong>Advocate for incentive payments</strong> to support hospitals and health systems鈥� transition to taking on higher levels of risk.</li> <li class="diamond">Advocate for implementing <strong>new voluntary payment models</strong> so hospitals are not forced to bear the expense of participation in these complicated programs if they do not believe it will benefit patients.</li> <li class="diamond"><strong>Create a permanent CMS hospital-at-home program</strong>, shown to be a safe and innovative approach to caring for patients in the comfort of their homes that leads to high patient satisfaction and, for some patients, results in shorter recovery times.</li> <li class="diamond"><strong>Remove barriers</strong> to cross-sector and interagency coordination and support investments to provide accountable care.</li> <li class="diamond"><strong>Make permanent coverage of certain telehealth services</strong> made possible during the COVID-19 pandemic, including lifting geographic and originating site restrictions, allowing Rural Health Clinics and Federally Qualified Health Centers to serve as distant sites, expanding practitioners who can provide telehealth and allowing hospital outpatient billing for virtual services, among others.</li> <li class="diamond"><strong>Implement a special registration process for telemedicine providers</strong> to ensure access to telemedicine prescribing of controlled substances for practitioners who register with the Drug Enforcement Agency. Preserve pandemic-era waivers until the special registration process begins.</li> </ul> </div> </li> </ul> </div> <div class="tabcontent" id="reducingcosts"> <ul class="a-container"> <li class="a-items"> Reducing Health Care System Costs for Patient Care <div class="a-content"> <ul class="diamond"> <li class="diamond"><strong>Ensure patients do not face financial barriers to care because of unaffordable deductibles or otherwise 鈥渟kinny coverage,鈥�</strong> such as health sharing ministries and short-term limited-duration coverage products.</li> <li class="diamond">Reduce the prevalence of individuals faced with unaffordable medical bills by <strong>addressing the root causes of medical debt</strong>, such as skyrocketing deductibles and other benefit designs that push costs onto consumers.</li> <li class="diamond"><strong>Support price transparency efforts by ensuring patients have access to the information they seek when preparing for care</strong>, including cost estimates when appropriate, and creating alignment of federal price transparency requirements to avoid patient confusion and overly burdensome duplication of efforts.</li> <li class="diamond">Advocate that No Surprises Act price transparency regulations leverage existing workflows and appropriate technology to <strong>enable patient access to information without significant administrative burden for providers.</strong></li> <li class="diamond">Reduce unnecessary costs in the system by pursuing <strong>medical liability reform.</strong></li> <li class="diamond">Reduce regulatory burden by identifying and advocating for the <strong>repeal of unnecessary and duplicative Conditions of Participation</strong> that increase hospital inefficiency and reduce the time providers can spend caring for their patients.</li> <li class="diamond"><strong>Mitigate unreasonable proposed changes to the False Claims Act and related enforcement practices.</strong></li> <li class="diamond"><strong>Preserve the ability of hospital and health system clinical laboratories to develop new and innovative diagnostic tests, known as laboratory-developed tests (LDT)</strong>, to address unmet patient needs and improve existing diagnostic tests without imposing burdensome and unnecessary regulatory oversight.</li> <li class="diamond"><strong>Ensure public policies are aligned across government regulatory bodies</strong> so hospitals are not held to conflicting regulations.</li> <li class="diamond"><strong>Reduce regulatory barriers to hospitals improving the environment</strong>, such as Medicare Conditions of Participation that lock hospitals into compliance with outdated and less energy-efficient physical plants or deter from efforts to reduce the use of anesthesia gases and inhalers.</li> <li class="diamond"><strong>Prevent the imposition or increase of tariffs on vital medical supplies</strong>, including drugs, devices and raw materials used to manufacture devices and drugs in the U.S., as these will further raise medical services costs and potentially force hospitals to use less effective alternatives that could increase the patient harm risk.</li> </ul> </div> </li> </ul> </div> function openCity(evt, cityName) { var i, tabcontent, tablinks; tabcontent = document.getElementsByClassName("tabcontent"); for (i = 0; i < tabcontent.length; i++) { tabcontent[i].style.display = "none"; } tablinks = document.getElementsByClassName("tablinks"); for (i = 0; i < tablinks.length; i++) { tablinks[i].className = tablinks[i].className.replace(" active", ""); } document.getElementById(cityName).style.display = "block"; evt.currentTarget.className += " active"; } // Get the element with id="defaultOpen" and click on it document.getElementById("defaultOpen").click(); </div> </div> <div class="container"> <hr> <h3>AHA Advocacy Campaigns</h3> <p>Please visit <a href="/advocacy/action-center">www.aha.org/advocacy/action-center</a> to get involved and learn more about the 黑料正能量 Association鈥檚 2025 public policy advocacy agenda.</p> </div> ul.diamond { list-style: none; margin-left: 20px; padding-left: 0; } li.diamond { padding-left: 1em; text-indent: 1em; } li.diamond:before { content: "鈼�"; color: #9d2235; padding-right: 10px; margin-left: -36px; } .resource-block-header .resource-block-title small { color: black; } </div> Wed, 15 Jan 2025 06:00:00 -0600 Making Healthcare More Affordable /aha-center-health-innovation-market-scan/2024-12-10-assessing-health-care-environment-2025 <div class="container"><div class="row"><div class="col-md-8"><img src="/sites/default/files/inline-images/Assessing-the-Health-Care-Environment-for-2025_0.png" data-entity-uuid="26b88094-b584-4174-8bce-4a0b75b739c7" data-entity-type="file" alt="Assessing the Health Care Environment for 2025. The cover of the 2025 Environmental Scan. Download your free copy today!" width="100%" height="100%"><p>Despite the significant upheaval in the retail health care sector over the past year, consumers still have plenty of choices for accessing care.</p><p>And as the recently released <a href="/environmentalscan">AHA 2025 Environmental Scan</a> points out, convenience in accessing care and affordability are primary drivers in consumers鈥� decision-making processes.</p><p>The AHA Environmental Scan contains data, surveys, trends, thought leadership and educational resources, illustrating some of the top issues facing the field, including workforce, financial stability, care delivery transformation and greater value. This scan can help leaders plan for the future of their organizations and consider ways the field can move forward together.</p><h2>Pay Close Attention to Access and Navigation</h2><p>In assessing factors that drive consumers to change providers or select a new provider, an Accenture survey from earlier this year highlighted the following:</p><ul><li><span><strong>89%</strong></span> of respondents said ease of navigation was the top factor that caused them to switch providers.</li><li><span><strong>70%</strong></span> cited access, which includes convenience, digital interaction, telehealth and customer service, as a top factor driving patients to select a new provider.</li><li><span><strong>53%</strong></span> said they selected a new provider based on a trusted physician or referral from a friend and the communication skills of the new provider.</li></ul><p>It鈥檚 worth noting that in navigational challenges cited by consumers, factors such as difficulty in doing business with the provider, bad experiences with the front desk or administrative staff, and problems with digital/online service and support solutions all weighed heavily in patients鈥� decisions to change providers.</p><h2>3 Ways to Improve the Consumer Navigation Experience</h2><p>Within the environmental scan, Lee Schwamm, M.D., senior vice president and chief digital health officer at Yale New Haven Health, offers three tips for creating an ideal digital state for consumers:</p><ul><li>Provide ubiquitous broadband and <span><strong>high-quality, affordable access</strong></span> not just for health care, but digital access in general, which will positively impact the social drivers of health.</li><li>Employ a <span><strong>cyber-secure platfor</strong></span><strong>m</strong> for data interoperability so devices and wearables can travel on a highly secure, standardized platform that is fully integrated with electronic health records.</li><li><span><strong>Deliver a better developed, autonomous layer/toolkit powered by artificial intelligence</strong></span> that would do much of the preprocessing and deliver standardization and uniformity. It must be equitable and accessible. Digital redlining is real.</li></ul><p>So, what do patients want from their overall digital health experiences and applications from providers? A report from Gozio Health this year found the following:</p><ul><li><span><strong>78%</strong></span> want to view or review lab tests in the providers鈥� apps.</li><li><span><strong>73%</strong></span> want to view their medical history online.</li><li><span><strong>73%</strong></span> want to message their providers within the apps.</li><li><span><strong>68%</strong></span> want to request medication refills through the apps.</li><li><span><strong>64%</strong></span> want to schedule appointments themselves through the apps.</li></ul><h2>Affordability Worries Many Consumers</h2><p>The rising cost of health insurance is another factor impacting consumers. Nearly one-third of consumers cited affordability as the most important factor in their health care experiences, noted a report this year from Huron Consulting.</p><p>Meanwhile, worries about being able to afford care and health insurance premiums are impacting a large percentage of the population, according to a Kaiser Family Foundation report from this past spring. That report found the following:</p><ul><li><span><strong>47%</strong></span> of adults reported that it is difficult to afford health care costs.</li><li><span><strong>48%</strong></span> of insured adults worried about affording their monthly insurance premiums.</li><li><span><strong>One in four</strong></span> said that in the past year they skipped or postponed getting the health care they need because of cost.</li><li><span><strong>One in five</strong></span> said they did not fill a prescription because of cost while a similar percentage said they instead opted for over-the-counter alternatives.</li></ul><p><a href="/environmentalscan"><span><strong>Download the AHA 2025 Environmental Sca</strong></span><strong>n</strong></a> for a more complete look at the issues impacting the health care landscape.</p></div><div class="col-md-4"><p><a href="/center" title="Visit the AHA Center for Health Innovation landing page."><img src="/sites/default/files/inline-images/logo-aha-innovation-center-color-sm.jpg" data-entity-uuid="7ade6b12-de98-4d0b-965f-a7c99d9463c5" alt="AHA Center for Health Innovation logo" width="721" height="130" data-entity- type="file" class="align-center"></a></p><p><a href="/center/form/innovation-subscription"><img src="/sites/default/files/2019-04/Market_Scan_Call_Out_360x300.png" data-entity-uuid data-entity-type alt width="360" height="300"></a></p></div></div></div>.field_featured_image { position: absolute; overflow: hidden; clip: rect(0 0 0 0); height: 1px; width: 1px; margin: -1px; padding: 0; border: 0; } .featured-image{ position: absolute; overflow: hidden; clip: rect(0 0 0 0); height: 1px; width: 1px; margin: -1px; padding: 0; border: 0; } h2 { color: #9d2235; } Tue, 10 Dec 2024 06:15:00 -0600 Making Healthcare More Affordable /environmentalscan/2024 <div> </div><div><div>.body p, .body li { font-size: 16px; } .scanLand { margin-bottom: 30px } .scanLand img { float: right; width: 50%; max-width: 300px; margin-left: 20px; border: 1px solid lightgrey } .scanLand h3 { font-size: 2em; margin-top: 0; margin-bottom: 20px } .col-md-4.scanLandForm { text-align: center } .scanLandForm { padding: 20px 20px 30px 20px; margin: 0 auto; background-color: #f6f6f6; max-width: 360px" } .scanLandForm h4 { margin-top: 0; text-align: center } .scanLandCallouts { margin: 30px auto; text-align: center } @media only screen and (max-width: 992px) { .scanLandCallouts { width: calc(50% - 20px); float: left; } .scanLandCallouts:nth-child(even) { margin-right: 30px; } .col-md-4 .scanLandForm { max-width: 360px; } } @media only screen and (max-width: 500px) { .scanLandCallouts { width: 100%; margin: 30px auto 0; } } @media only screen and (max-width: 500px) { .scanLand img { width: 100%; margin: 0 auto 30px; float: none } .mktoButtonRow { margin-left: -20px !important; } @media only screen and (max-width: 350px) { margin-left: -60px !important; } } </div><div class="container"><div class="row"><div class="col-md-8 scanLand"><img src="/sites/default/files/2023-11/Environmental-Scan-2024-cover_700x906.jpg" alt="2024 Environmental Scan cover" width="700" height="906"><h3>Implications for the coming year and beyond</h3><p>The 2024 AHA Environmental Scan explores current data and trends to help the health care field think strategically about the future, while also providing an opportunity to reflect on the changes, challenges and opportunities we鈥檝e experienced over the past few years. This annual publication can spark discussion and engagement with hospital and health system staff, leaders, boards and community stakeholders.</p><p><strong>Topics include:</strong></p><ul><li><strong>Hospital and health system landscape:</strong> Financial and operational challenges and care in alternative settings.</li><li><strong>Workforce:</strong> Shortages, resiliency and technology to enhance the workforce experience.</li><li><strong>Better care and greater value:</strong> Patient safety culture and risks, value-based care and emerging care delivery transformation models.</li><li><strong>Consumerism:</strong> Retail clinic trends, digital tools and 鈥渋nfodemic鈥� management strategies.</li><li><strong>Trend snapshots:</strong> Public trust, coverage, artificial intelligence and climate鈥檚 impact on health.</li></ul><p><em>The 2024 Environmental Scan is sponsored by </em><a href="https://www.amnhealthcare.com/healthcare-staffing-services/?utm_source=thirdpartywebsite&utm_medium=Content&utm_campaign=ClientAMN_AHAEnvironmentalScan_2024&LO=AHA.com" title="AMN Healthcare | Innovative Staffing and Workforce Solutions"><em>AMN Healthcare Leadership Solutions</em></a></p><h4><small>Also Available:</small></h4><p>The 2024 Environmental Scan <a href="/system/files/media/file/2023/12/Environmental_Scan_2024-Leadership-Discussion-Guide.pdf" target="_blank" title="Leadership Discussion Guide"><strong>Leadership Discussion Guide</strong></a> helps hospitals and other stakeholders use the scan to strategize and think about key issues.</p><p>An <em>AHA member-only</em> <a href="/presentation-resource/2023-11-28-2024-environmental-scan-presentation" target="_blank" title="Members Only - PowerPoint presentation"><strong>PowerPoint presentation</strong></a> is designed to help share 2024 Environmental Scan insights with various stakeholders and your community.</p><p>The <a href="/aha-workforce-scan" target="_blank"><strong>2024 AHA Health Care Workforce Scan</strong></a> will help you better understand the latest forces and trends affecting health care human resources. This resource provides workforce insights to guide your organization forward during this time of continued transformation.</p><p>The AHA鈥檚 Society for Health Care Strategy & Market Development (SHSMD) offers a deep dive into key forces that are transforming the future of health care through <a href="https://www.shsmd.org/futurescan" target="_blank">Futurescan</a>.</p></div><div class="col-md-4"> <h4>Fill out the form below to get your copy today!</h4>   MktoForms2.loadForm("//sponsors.aha.org", "710-ZLL-651", 2879);</div>--><div class="panel panel-default"><div class="panel-heading"><h3>Environmental Scan</h3></div><div class="panel-body"><p><a class="btn btn-wide btn-primary" href="/environmentalscan" rel="noopener noreferrer nofollow" data-view-context="top-level-view">Latest Edition</a></p></div></div><div class="scanLandCallouts"><a href="/center/emerging-issues/market-insights"><small><img src="/sites/default/files/2019-11/Market_Insights_Call_Out_340X104_0.jpg" alt="market insights callout" width="360" height="104"></small></a></div><div class="scanLandCallouts"><a href="/center/form/innovation-subscription"><small><img src="/sites/default/files/2019-11/Market_Scan_Call_Out_340X104_0.jpg" alt="market scan callout" width="360" height="104"></small></a></div></div></div></div></div> Tue, 03 Dec 2024 10:00:00 -0600 Making Healthcare More Affordable <div class="raw-html-embed"> </div><div><div> .body p, .body li { font-size: 16px; } .scanLand { margin-bottom: 30px } .scanLand img { float: right; width: 50%; max-width: 300px; margin-left: 20px; border: 1px solid lightgrey } .scanLand h3 { font-size: 2em; margin-top: 0; margin-bottom: 20px } .col-md-4.scanLandForm { text-align: center } .scanLandForm { padding: 20px 20px 30px 20px; margin: 0 auto; background-color: #f6f6f6; max-width: 360px" } .scanLandForm h4 { margin-top: 0; text-align: center } .scanLandCallouts { margin: 30px auto; text-align: center } @media only screen and (max-width: 992px) { .scanLandCallouts { width: calc(50% - 20px); float: left; } .scanLandCallouts:nth-child(even) { margin-right: 30px; } .col-md-4 .scanLandForm { max-width: 360px; } } @media only screen and (max-width: 500px) { .scanLandCallouts { width: 100%; margin: 30px auto 0; } } @media only screen and (max-width: 500px) { .scanLand img { width: 100%; margin: 0 auto 30px; float: none } .mktoButtonRow { margin-left: -20px !important; } @media only screen and (max-width: 350px) { margin-left: -60px !important; } } </div><div class="container"><div class="row"><div class="col-md-8 scanLand"><img src="/sites/default/files/2024-12/Environmental-Scan-v2-2025-cover_700x906.jpg" alt="2025 Environmental Scan cover" width="700" height="906"><h3>Implications for the coming year and beyond</h3><p>The 2025 AHA Environmental Scan offers invaluable insights into the latest data and emerging trends, empowering the health care field to plan strategically for the future. The scan gives us the chance to reflect on the challenges we face and the opportunities that await us. By understanding where we are, we can more clearly see where we can go and why it matters. This annual publication serves as a catalyst for meaningful conversations among hospital and health system leaders, boards, staff and community stakeholders as we collectively shape the future of health care.</p><p><strong>Topics include:</strong></p><ul><li><strong>Hospital and health system landscape:</strong> Financial challenges, supply chain shortages, cybersecurity and the impact of commercial insurer claim denials.</li><li><strong>Workforce:</strong> Vacancy rates, remote work trends and technology advancements.</li><li><strong>Better care and greater value:</strong> Improvements in patient safety and quality measures, value-based payment models, strategies to address social needs and maternal health.</li><li><strong>Consumerism:</strong> The impact of GLP-1 drugs, consumers鈥� views on GenAI, digital patient engagement and health care affordability.</li><li><strong>Trend snapshots:</strong> Public trust, aging in the U.S., coverage, behavioral health, rural health, climate鈥檚 impact on health, hospital-based violence intervention programs and vaccines.</li></ul><p><em>The 2025 Environmental Scan is sponsored by </em><a href="https://www.besmith.com" title="B.E. Smith, an AMN Healthcare"><em>B.E. Smith, an AMN Healthcare company.</em></a></p><h4><small>Also Available:</small></h4><p>The 2025 Environmental Scan <a href="/system/files/media/file/2024/11/2025_Environmental_Scan_Leadership_Guide.pdf" target="_blank" title="Leadership Discussion Guide"><strong>Leadership Discussion Guide</strong></a> helps hospitals and other stakeholders use the scan to strategize and think about key issues.</p><p>An <em>AHA member-only</em> <a href="/presentation-resource/2024-11-26-2025-environmental-scan-presentation" target="_blank" title="Members Only - PowerPoint presentation"><strong>PowerPoint presentation</strong></a> is designed to help share 2025 Environmental Scan insights with various stakeholders and your community.</p><p>The <a href="/aha-workforce-scan" target="_blank"><strong>2025 AHA Health Care Workforce Scan</strong></a> will help you better understand the latest forces and trends affecting health care human resources. This resource provides workforce insights to guide your organization forward during this time of continued transformation.</p><p>The AHA鈥檚 Society for Health Care Strategy & Market Development (SHSMD) offers a deep dive into key forces that are transforming the future of health care through <a href="https://www.shsmd.org/futurescan" target="_blank"><strong>Futurescan</strong></a>.</p></div><div class="col-md-4"><div class="scanLandForm"><h4>Fill out the form below to get your copy today!</h4>   MktoForms2.loadForm("//sponsors.aha.org", "710-ZLL-651", 4277); </div><div class="scanLandCallouts"><a href="/center/emerging-issues/market-insights"><small><img src="/sites/default/files/2019-11/Market_Insights_Call_Out_340X104_0.jpg" alt="market insights callout" width="360" height="104"></small></a></div><div class="scanLandCallouts"><a href="/center/form/innovation-subscription"><small><img src="/sites/default/files/2019-11/Market_Scan_Call_Out_340X104_0.jpg" alt="market scan callout" width="360" height="104"></small></a></div></div></div></div></div> Tue, 03 Dec 2024 10:00:00 -0600 Making Healthcare More Affordable /affordability-advocacy-agenda <div class="container"><div class="row"><div class="col-md-8"><h2><span>Advancing Affordability, Value, and Equity in Health Care Priorities for America鈥檚 Hospitals and Health Systems</span></h2><p>By all accounts 2020 was an unprecedented and historic year 鈥� one that tested our nation, our economy and our health care system like never before.</p><p>Hospitals, health systems and post-acute care providers 鈥� along with our doctors, nurses and other team members 鈥� have been on the front lines of the COVID-19 pandemic, working tirelessly to provide the best care for patients, families and communities. They have done this 鈥� and continue to do this 鈥� while facing daunting challenges. These challenges have persisted well into 2021, with continued surges of cases and hospitalizations.</p><p>At the same time, individuals, employers, and the government continue to seek greater value for their health care dollars. Concerns around the affordability of health care will only grow as overall health care spending continues to rise and, especially with respect to publicly-financed programs like Medicare and Medicaid, demographic trends mean that there are fewer workers to help finance this care. There is also a renewed focus on eliminating disparities in care, closing equity gaps, and enhancing quality and patient safety 鈥� all of which are integral to achieving greater value.</p><p>Our shared focus with Congress and Administration is on providing relief from the pandemic, ensuring a smooth recovery, and rebuilding a better health care system for the future. The 黑料正能量 Association continues to incorporate principles that promote improved affordability, value, and equity into our policy and advocacy activities. Below are some of our key priorities in these areas.</p><h3><span>Making Health Care More Affordable</span></h3><p>In recent years, health care spending growth has largely been driven by increased use and intensity of services. In other words, more people are getting care 鈥� and more care 鈥� and the care they are getting is more involved than in the past. Much of this is the result of substantial expansions in health care coverage, improved efforts to connect people to needed care, advances in medicine and technology, and growth in the prevalence of chronic disease. In some cases, prices have also risen, such as for prescription drugs. This can impact not only what individuals may pay at the pharmacy counter but also the cost of care provided by hospitals, physicians, and other providers that relies on critical drug therapies. Another substantial cost driver that has dramatically escalated in the past several years is the utilization management processes that health plans have erected and which require significant investments in technology and personnel to manage.</p><p>Hospital care requires a range of inputs such as wages for clinical and other personnel, prescription drugs, administrative software and other technology, food, medical devices, utilities and professional insurance. Steep increases in the prices for certain inputs, like drugs and administrative processes mandated by health plans, can undermine hospitals鈥� efforts to reduce the cost of care.</p><p>To address the underlying cost drivers in the health care system, we urge Congress and the Administration to:</p><ul><li>Rein in the rising cost of drugs, including by taking steps to increase competition among drug manufacturers; improve transparency in drug pricing; and advance value-based payment models for drugs.</li><li>In the same vein, protect the 340B drug savings program to ensure structurally marginalized communities have access to more affordable drug therapies by reversing harmful policies and holding drug manufacturers accountable to the rules of the program, especially as it relates to community pharmacy arrangements.</li><li>Reduce administrative waste by streamlining prior authorization requirements and processes for hospitals and post-acute care providers, so that clinicians can spend more of their time and resources on direct patient care, not pushing paper and arguing with insurance companies over administrative delays and coverage denials.</li><li>Promote greater efficiency and safeguards against unnecessary burden in HIPAA administrative standards and other rules related to billing and ensure an achievable roadmap toward greater adoption of standard transactions.</li><li>Reduce unnecessary costs in the system by passing comprehensive medical liability reform, including caps on non-economic damages and allowing courts to limit attorneys鈥� contingency fees.</li></ul><h3><span>Improving the Affordability of Coverage</span></h3><p>In addition, we urge Congress and the Administration to take additional steps to make health care coverage more affordable and easier to use for patients. The entire point of insurance is to share large and unanticipated costs across a pool of people. Coverage is essential for making health care affordable for individuals and families in the same way car insurance enables individual drivers to weather the bad fortune of an unexpected crash. While we have made substantial gains in health coverage over the past decade, we are just beginning to fully understand the crisis of under-insurance that is primarily being driven by high deductible health plans.</p><p>The AHA supports bolstering our current public/private framework for coverage to close the remaining coverage gaps and taking immediate steps to ensure that patients do not face financial barriers to using their coverage. We encourage policymakers to preserve and build on the strong foundation of employer-sponsored coverage and further strengthen the individual market while ensuring that Medicare and Medicaid are available to those who rely on these programs. Specifically, we encourage Congress and the Administration to:</p><ul><li>Take additional steps to close coverage gaps, including by building on the existing incentives to encourage all states to expand Medicaid, making permanent the recent expansions in eligibility and the level of subsidies for coverage on the Health Insurance Marketplaces, and expanding existing outreach and enrollment efforts to ensure that every U.S. resident knows their options for coverage.</li><li>End the sale of products purporting to be health plans but that do not meet all of the consumer protections established in federal law, such as health sharing ministries and short-term limited duration coverage products which can leave patients with high and unexpected medical bills as a result of gaps in coverage.</li><li>Restrict the sale of high deductible health plans to consumers who can afford the associated cost-sharing obligations.</li><li>Ensure patients can rely on their coverage by disallowing health plans from inappropriately delaying and denying care, including by making mid-year coverage changes.</li><li>Protect patients from surprise medical bills and ensure that the implementing regulations do not unintentionally distort health care markets and reduce patient access to care.</li><li>Support price transparency efforts by ensuring patients have access to the information they seek when preparing for care, including cost estimates when appropriate, and creating alignment of federal price transparency requirements to avoid patient confusion and overly burdensome duplication of efforts.</li></ul><h2><span>Advancing Value through Health System Transformation and Enhancements in Quality</span></h2><h3><span>Health System Transformation</span></h3><p>In addition to making the health care system more affordable, hospitals and health systems are committed to ensuring that each dollar brings value. We will achieve this by continuously striving to deliver the highest quality care most efficiently, and that will require rethinking how and where we deliver care. We will also look for opportunities for providers to collaborate with payers and employers to ensure aligned incentives to achieve value, including identifying effective models of risk where appropriate.</p><p>The last decade brought significant changes in the health care landscape, but nothing has accelerated changes in the delivery of health care like the COVID-19 pandemic. During the public health emergency, hospitals and health systems were able to innovate at a pace and scale previously unseen as a result not only of the realities of containing a pandemic but also the regulatory flexibility provided by states and the federal government.</p><p>The AHA is eager to continue these advances and supports policies that:</p><ul><li>Expand use of telehealth, broadband and digital technologies by providing Medicare and Federal Communications Commission funding, coverage, and reimbursement for such services, technology and workforce training.</li><li>Implement policies to better integrate and coordinate behavioral health services with physical health services.</li><li>Build on the progress in modernizing the Stark Law and Anti-kickback Statute regulations that better protect arrangements that promote value-based care.</li><li>Allow providers to determine how best to utilize electronic health records (EHRs) and other technologies while promoting interoperability and access to health information for clinical care and patient engagement.</li><li>Provide robust support to ensure electronic communication between acute care hospitals and psychiatric hospitals and providers, and to encourage psychiatric hospitals and mental health providers to optimally use EHRs.</li><li>Advance use of innovative technologies and software (e.g., clinical decision support algorithms) without increasing regulatory burden by supporting policies that enable clinicians to have the data they need to treat patients and improve health outcomes.</li><li>Invest in health care infrastructure by expanding access to virtual care technologies and high-speed internet, strengthening the capacity and capability for emergency preparedness and response, assisting hospitals in 鈥渞ight-sizing鈥� to meet the needs of their communities, and ensuring adequate financing mechanisms are in place for hospitals and health systems, including for training the workforce.</li><li>Address the impact that social determinants of health have on patient outcomes by improving care coordination and expanding the tools hospitals can use to meet these needs.</li><li>Advance rural health care alternatives to ensure sustainable care delivery and financing including: exploring rural pre-payment models; supporting additional inpatient/outpatient transformation strategies; promoting virtual care strategies; allowing innovative partnerships; and refining existing models that support hospitals serving historically marginalized communities.</li><li>Explore a new payment mechanism for metropolitan anchor institutions that treat a disproportionate number of government-funded or uninsured patients.</li></ul><h3><span>Enhancing Quality and Patient Safety</span></h3><p>America鈥檚 hospitals and health systems are world-renowned for the quality of care they provide and are always striving to do even better. Clinicians at U.S. hospitals set the global standard in COVID-19 care, such as by optimizing the use of ventilators for those patients who would most benefit from them. 鈥� knowledge that was then shared around the world.</p><p>There is no limit to hospitals鈥� and health systems鈥� commitment to quality. However, policy changes are needed to facilitate the identification and adoption of best clinical practices, including addressing challenges with public quality reporting and incentive programs. The AHA encourages policymakers to:</p><ul><li>Continue to streamline and coordinate quality measures in national programs to focus on the 鈥渕easures that matter鈥� most to improving health and outcomes while reducing burden on providers. These measures should be based on evidence that demonstrates meaningful improvements in patient outcomes are achievable by improving adherence to the measures.</li><li>Advocate for modernized conditions of participation, interpretative guidance and Joint Commission standards that hold hospitals accountable for taking actions that lead to higher-quality and safer care.</li><li>Enhance the effectiveness of the physician quality payment program by advocating for more accurate and meaningful cost measures and data-driven implementation of new program approaches.</li><li>Promote advanced illness management to better honor patients鈥� wishes at the end-of-life and remove barriers to expanding access to palliative care services.</li><li>Enhance care coordination and improve patient safety by implementing through rulemaking Sec. 3221 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which revises and better aligns the outdated 42 CFR Part 2 regulations with HIPAA, allowing the responsible sharing of substance use disorder treatment records for the purposes of treatment, payment and health care operations.</li></ul><h3><span>Advancing Health Equity, Eliminating Health Care Disparities, and Increasing Diversity and Inclusion</span></h3><p>The COVID-19 outbreak in the U.S. has shown the country what all hospital and health systems leaders have known for years: serious gaps exist in access, cost and quality for patients based on race, ethnicity, gender and gender identity, age, sexual orientation or other demographic and socio-economic factors. Hospitals and health systems are committed to doing the work to address health equity issues. The AHA and its Institute for Diversity and Health Equity (IFDHE) are also committed to advancing health equity, eliminating health care disparities and increasing diversity and inclusion. The AHA supports policies that:</p><ul><li>Pursue strategies and support public policies aimed at improving maternal and child health outcomes with a particular focus on eliminating racial and ethnic disparities.</li><li>Promote health equity by encouraging cultural humility training in medical residency programs and in-service training for health care professionals.</li><li>Promote inclusion of adjustment for sociodemographic factors in quality measurement programs where appropriate to ensure performance measurement and payment adjustments support the efforts to make meaningful improvements.</li><li>Support coordinated collection of race and ethnicity data across federal agencies to elevate understanding of health care needs in Black and Latino Americans, Native Americans and other communities of color.</li><li>Increase funding for the health equity infrastructure in the Department of Health and Human Services, including the National Institute on Minority Health and Health Disparities, to better research and address the needs of communities of color.</li><li>Support efforts to increase diversity in the health care workforce, including through federal grants to minority-serving institutions for scholarships.</li><li>Repeal the June 2020 final rule that narrowed the scope of non-discrimination protections under Section 1557 of the Affordable Care Act.</li></ul></div><div class="col-md-4"><p><a href="/system/files/media/file/2019/09/report-affordability-agenda-0919.pdf" target="_blank" title="Click here to download the AHA Affordability Advocacy Agenda 2021 PDF."><img src="/sites/default/files/inline-images/Page-1-Affordability-Advocacy-Agenda-2021-10-15.jpg" data-entity-uuid="f0cf703c-d05d-4774-9ecd-c00015b522d3" data-entity-type="file" alt="Page one of the AHA Affordability Advocacy Agenda 2021." width="2550" height="3311"></a></p><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2019/09/report-affordability-agenda-0919.pdf" target="_blank" title="Click here to download the AHA Affordability Advocacy Agenda 2021 PDF.">Download PDF</a></div><p><a href="/costsofcaring" target="_blank" title="Click here for more information."><img src="/sites/default/files/2022-08/costs-of-caring-report-cover_Page_1.png" data-entity-uuid data-entity-type="file" alt="Costs of Caring 2022 Cover." width="1159" height="1500"></a></p><div class="external-link spacer"><a class="btn btn-primary btn-wide" href="/system/files/media/file/2022/04/2022-Hospital-Expenses-Increase-Report-Final-Final.pdf" target="_blank">Download PDF</a></div><div class="panel module-typeC"><div class="panel-heading"><h3 class="panel-title">Affordability Resources</h3></div><div class="panel-body group2"><p><a href="/issue-brief/2019-09-18-real-affordability-solutions-front-lines-caring" target="_blank" title="Click here to go to the Real Affordability Solutions from the Front Lines of Caring landing page.">Real Affordability Solutions from the Front Lines of Caring</a></p><p><a href="/costsofcaring" target="_blank" title="Click here to view the Cost of Caring report.">Cost of Caring</a></p><p><a href="/standardsguidelines/2021-10-08-partnerships-mergers-and-acquisitions-can-provide-benefits-certain" target="_blank">Partnerships, Mergers, and Acquisitions Can Provide Benefits to Certain Hospitals and Communities</a></p><p><a href="/guidesreports/2021-09-21-financial-effects-covid-19-hospital-outlook-remainder-2021" target="_blank">Financial Effects of COVID-19: Hospital Outlook for the Remainder of 2021</a></p><p><a href="/guidesreports/2021-09-09-results-2018-tax-exempt-hospitals-schedule-h-community-benefit-reports" target="_blank">Results from 2018 Tax-Exempt Hospitals鈥� Schedule H Community Benefit Reports</a></p><p><a href="/news/perspective/2021-10-08-perspective-confronting-commercial-insurers-practices-threaten-patient" target="_blank">Perspective: Confronting Commercial Insurers鈥� Practices that Threaten Patient Care</a></p><p><a href="/news/blog/2021-07-12-lown-institute-report-hospital-community-benefits-falls-short" target="_blank">Lown Institute Report on Hospital Community Benefits Falls Short</a></p><p><a href="/news/headline/2021-09-28-study-health-insurance-market-becoming-more-concentrated">Study: Health insurance market becoming more concentrated</a></p><p><a href="https://www.ama-assn.org/delivering-care/patient-support-advocacy/competition-health-insurance-research">Report: American Medical Association Report on Competition in the Health Insurance</a></p></div></div></div></div></div> Tue, 13 Aug 2024 10:00:00 -0500 Making Healthcare More Affordable /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>黑料正能量 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>鈥淲hat Can Congress Do to End the Medical Debt Crisis in America?鈥�</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 鈥� including more than 270,000 affiliated physicians, 2 million nurses and other caregivers 鈥� and the 43,000 health care leaders who belong to our professional membership groups, the 黑料正能量 Association (AHA) writes to share the hospital field鈥檚 comments on medical debt. While we appreciate Congress鈥檚 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鈥� 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 鈥�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.鈥�<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鈥� 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鈥� 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鈥� 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 鈥渕eaningful barrier to effective understanding and use of preventive service benefits.鈥�<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鈥檚 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鈥檚 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鈥檚 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鈥檚 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 鈥減resumptive eligibility鈥� 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鈥� 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鈥檚 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 Making Healthcare More Affordable /news/perspective/2024-03-22-supercharging-our-efforts-strengthen-americas-health-care <p>The trends and events shaping the future of health care demonstrate that tending to business as usual 鈥� the status quo 鈥� just won鈥檛 cut it anymore.</p><p>The good news is that new thinking, new focus and renewed determination to address our field鈥檚 challenges are happening across many fronts in ways that promise to help strengthen our future and protect patient access to care.</p><p>As part of those efforts, we were pleased to share this week that the Coalition to Protect America鈥檚 Health Care, which for 24 years has fought to protect access to high-quality care for all Americans, will now be known as the <a href="https://strengthenhealthcare.org" target="_blank" title="Coalition to Strengthen America's Healthcare website">Coalition to Strengthen America鈥檚 Healthcare: Protecting 24/7 Care</a><strong>. </strong>The AHA is a founding member of the Coalition, which is currently supported by all the national hospital associations, as well as allied associations, and hospitals and health systems around the country.</p><p>The new name reflects its renewed focus to protect and strengthen patients鈥� access to 24/7 care across the country.</p><p>Shakespeare famously asked in <em>Romeo and Juliet</em>, 鈥淲hat's in a name?鈥� The answer is: It鈥檚 more than a name change, it鈥檚 an expansion of the intentionality behind it. </p><p>The rebranding campaign will support the Coalition鈥檚 expanded capacity as a proactive, always-on organization dedicated to positively shaping public perception of hospitals and health systems, neutralizing opposition attacks, and holding corporate payers accountable for their role in delaying and denying care while driving up overall health care costs. These activities will complement and help supercharge all of the efforts the AHA is leading.</p><p>We are grateful to former AHA Board Chair Nancy Howell Agee, CEO of Carilion Clinic, who chairs the Coalition, for her leadership of this important effort.</p><p>As Nancy notes, 鈥淭he best way to support patients and communities throughout America is to support and strengthen America鈥檚 hospitals and health systems. That鈥檚 why we are renewing our focus and redoubling our efforts to protect and strengthen patients鈥� access to high-quality, around-the-clock care.鈥�</p><p>The Coalition is a community of more than 2 million advocates committed to defending and strengthening patient care in America鈥檚 hospitals. Through its efforts, which includes grassroots advocacy, the Coalition has been very effective protecting access to care for patients. And as part of the rebrand and launch, the Coalition will be increasing its efforts to empower the community to speak up for the strong 24/7 hospital care they want and deserve.</p><p>You鈥檒l also see the Coalition implementing comprehensive campaigns that use paid and earned media, digital, local and grassroots advocacy strategies, and research to influence voters, stakeholders and policymakers.</p><p>Hospitals and health systems are the foundation of our entire health care system. A strong, healthy future for the American people requires strong, healthy hospitals and health systems.</p><p>Please take a few minutes to learn more about the <a href="https://strengthenhealthcare.org/" target="_blank" title="Coatlition to Strengthen America's Healthcare website.">Coalition</a> and how you, your organization and your community can get involved. We鈥檒l continue to share information about the Coalition鈥檚 activities and appreciate your continued support in our collective effort to advance health in America.</p><p><em><u>P.S.</u></em></p><p>Wanted to say that the story 鈥� both in the short-term and long-term 鈥� continues to be written about the cyberattack on Change Healthcare. There will be plenty of lessons learned, but one key observation so far is that as the government looks at cybersecurity in health care and hospitals, they need to make sure they address the key area of vulnerability: third-party vendors, which have been the source of many recent intrusions.</p><p>Another area of examination is the deep tentacles that UnitedHealth Group has in our health care system. According to the Wall Street Journal, UHG is now the target of a Department of Justice antitrust investigation, which is not related to the cyberattack. You may recall the AHA opposed the Change merger in the first place and worked to get the DOJ to challenge it, but they lost in court.</p><p>Keep up to date on the Change Healthcare cyberattack by visiting our <a href="/cybersecurity/change-healthcare-cyberattack-updates" target="_blank" title="Change Healthcare webpate">webpage</a>.</p> Fri, 22 Mar 2024 08:45:44 -0500 Making Healthcare More Affordable <p class="text-align-center"><strong>Statement</strong><br><strong>of the</strong><br><strong>黑料正能量 Association</strong><br><strong>for the</strong><br><strong>Subcommittee on Health</strong><br><strong>of the</strong><br><strong>Committee on Energy and Commerce</strong><br><strong>U.S. House of Representatives</strong><br><strong>鈥淗ealth Care Spending in the United States: Unsustainable for Patients, Employers, and Taxpayers鈥�</strong><br><strong>January 31, 2024</strong></p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners 鈥� including more than 270,000 affiliated physicians, 2 million nurses and other caregivers 鈥� and the 43,000 health care leaders who belong to our professional membership groups, the 黑料正能量 Association (AHA) writes to share the hospital field鈥檚 comments on the topic of national health expenditures.</p><h2>OVERVIEW OF NATIONAL HEALTH SPENDING</h2><p>We welcome the opportunity to provide comments to the subcommittee regarding health care spending. America鈥檚 hospitals and health systems 鈥� physicians, nurses and other caregivers 鈥� 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. However, government payers continue to pay below the cost of care, and commercial insurers are erecting barriers to payment. 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><h3>Commercial Insurer Accountability</h3><p>To truly reduce health care costs, we urge the subcommittee to address practices by certain commercial health insurers. Additional oversight is needed to ensure that certain 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, recently released 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 鈥� in fact, annual insurance premiums increased nearly twice as much as hospital prices over a ten-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 report from the Department of Health and Human Services (HHS) Office of Inspector General in 2022 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 鈥� covering more than half of all Medicare beneficiaries 鈥� 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 are also a major burden to the health care workforce and contribute to provider burnout.</p><p>We urge the subcommittee to pass legislation to build on these regulations with further oversight of the MA program, including greater data collection and reporting on plan performance and more streamlined pathways to report suspected violations of federal rules.</p><h3>Prescription Drug Prices</h3><p>The subcommittee should also 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 recent report 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>3</sup> These increases were higher than the rate of inflation, which was 3.4% in December.</p><p>A report by the Assistant Secretary for Planning & Evaluation at HHS found that drug companies increased drug prices for 1,216 drugs 鈥� many used to treat chronic conditions like cancer and rheumatoid arthritis 鈥� by more than the rate of inflation, which was 8.5% between 2021 and 2022.<sup>4</sup> In fact, the average price increase for these drugs was 31.6%, with some drugs experiencing price increases as much as 500%. Moreover, recent drug shortages, specifically for certain drugs used to treat cancer, have also fueled further expense growth. It is estimated that drug shortages alone cost hospitals nearly $360 million a year.<sup>5</sup></p><h2>SITE-NEUTRAL PAYMENT POLICIES</h2><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鈥� offices, while also being held to stricter safety and regulatory requirements.</p><p>This is especially true in rural communities. Medicare beneficiaries in rural areas 鈥� including those who are dually eligible for Medicaid 鈥� disproportionately rely on HOPDs to meet their increased health care needs since they have less access to office-based physicians.<sup>6</sup> Additional Medicare cuts to these facilities will have a direct impact on the level of care and services available to vulnerable patients in rural communities.</p><p>The AHA opposes provisions in H.R. 5378, the Lower Costs, More Transparency Act (LCMTA), to expand site-neutral payment cuts to include essential drug administration services furnished in off-campus HOPDs. This policy disregards important differences in patient safety and quality standards required in these facilities. Unlike other sites of care, hospitals take additional steps to make certain that drugs are prepared and administered in a safe manner for both patients and providers.<sup>7</sup> For example, hospital pharmacists are available on-site to confirm safe dosing and check for drug interactions. Hospitals also provide patients with rapid access to comprehensive wraparound services and multidisciplinary care coordination. In addition, hospitals must adhere to multiagency federal and state regulatory standards to ensure safety oversight, including those required by the Food and Drug Administration, U.S. Pharmacopeia and The Joint Commission.</p><p>The cost of care delivered in hospitals and health systems considers the unique benefits they provide to their communities, and 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 analysis 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.<sup>8</sup> As a result, two-thirds of all hospitals reported negative Medicare margins in 2022.</p><p>Any additional site-neutral cuts would exacerbate these financial challenges and reduce access to essential care and services in communities, especially those in rural and underserved areas.</p><h3>Separate Unique Health Identifier</h3><p>The AHA opposes the provision in the LCMTA that would require each off-campus HOPD to be assigned a separate unique health identifier from its provider. This is unnecessary since hospitals are already transparent about the location of care delivery on their bills. Hospitals and other providers bill according to federal regulations, which require them to bill all payers 鈥� Medicare, Medicaid and private payers 鈥� 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 provision 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鈥� 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.</p><h2>PRICE TRANSPARENCY REQUIREMENTS</h2><p>We appreciate the subcommittee鈥檚 ongoing interest in hospital price transparency to provide consumers with the price information they need specific to their course of treatment. However, in seeking to codify the Hospital Price Transparency Rule that went into effect in January 2021, the provisions of LCMTA undermine the work hospitals have done to provide price information to consumers and are redundant to recent actions taken by CMS.</p><p>Hospitals and health systems have invested considerable time and resources to comply with the conditions of 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 90.7% of hospitals have met the requirement to post a machine-readable file, and 83.1% have included a substantial amount of negotiated rates (see Figure 1).<sup>9</sup></p><p><img src="/sites/default/files/2024-01/figure-1-aha-statement-health-care-spending-in-the-us-unsustainable-for-patients-employers-and-taxpayers-1-31-24.png" width="911" height="308" alt="Figure 1. 6,357 Total Hospitals. 650 Total Health Systems. 1,119,207,976 Total Negotiated Rates. 5,763 posted MRF: 90.7%. 5,280 have negotiated rates: 83.1%. 4,911 have cash rates: 77.3%. 5,109 have surgery rates: 80.4%. 5,134 have imaging rates: 80.8%. 5,170 have BUCAH rates: 81.3%. 4,137 have DRG rates: 65.1%. 4,412 have drug rates: 69.4%."></p><p>One of the most significant changes from the current rule would be that the LCMTA no longer recognizes 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鈥檚 annual deductible. This is a very 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 change to hospital transparency requirements.</p><h2>CONCLUSION</h2><p>Thank you for your consideration of the AHA鈥檚 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.<br>__________</p><p><small class="sm"><sup>1</sup> </small><a class="ck-anchor" href="/system/files/media/file/2022/04/2022-Hospital-Expenses-Increase-Report-Final-Final.pdf" id="/system/files/media/file/2022/04/2022-Hospital-Expenses-Increase-Report-Final-Final.pdf"><small class="sm">/system/files/media/file/2022/04/2022-Hospital-Expenses-Increase-Report-Final-Final.pdf</small></a><small class="sm"> </small><br><small class="sm"><sup>2</sup> </small><a class="ck-anchor" href="https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf" id="https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf"><small class="sm">https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf</small></a><br><small class="sm"><sup>3</sup> </small><a class="ck-anchor" href="https://www.wsj.com/health/pharma/drugmakers-raise-prices-of-ozempic-mounjaro-and-hundreds-of-other-drugs-bdac7051" id="https://www.wsj.com/health/pharma/drugmakers-raise-prices-of-ozempic-mounjaro-and-hundreds-of-other-drugs-bdac7051"><small class="sm">https://www.wsj.com/health/pharma/drugmakers-raise-prices-of-ozempic-mounjaro-and-hundreds-of-other-drugs-bdac7051</small></a><small class="sm"> </small><br><small class="sm"><sup>4</sup> </small><a class="ck-anchor" href="https://aspe.hhs.gov/reports/prescription-drug-price-increases" id="https://aspe.hhs.gov/reports/prescription-drug-price-increases"><small class="sm">https://aspe.hhs.gov/reports/prescription-drug-price-increases</small></a><small class="sm"> </small><br><small class="sm"><sup>5</sup> </small><a class="ck-anchor" href="https://www.axios.com/2023/03/21/drug-shortages-upend-cancer-treatments" id="https://www.axios.com/2023/03/21/drug-shortages-upend-cancer-treatments"><small class="sm">https://www.axios.com/2023/03/21/drug-shortages-upend-cancer-treatments</small></a><small class="sm"> </small><br><small class="sm"><sup>6</sup> </small><a class="ck-anchor" href="/system/files/media/file/2024/01/analysis-hospitals-health-systems-are-critical-to-preserving-access-to-care-for-rural-communities-report.pdf" id="/system/files/media/file/2024/01/analysis-hospitals-health-systems-are-critical-to-preserving-access-to-care-for-rural-communities-report.pdf"><small class="sm">/system/files/media/file/2024/01/analysis-hospitals-health-systems-are-critical-to-preserving-access-to-care-for-rural-communities-report.pdf</small></a><small class="sm"> </small><br><small class="sm"><sup>7</sup> </small><a class="ck-anchor" href="/system/files/media/file/2023/11/Reject-Site-Neutral-Payment-for-Lower-Standards-of-Infusion-Care.pdf" id="/system/files/media/file/2023/11/Reject-Site-Neutral-Payment-for-Lower-Standards-of-Infusion-Care.pdf"><small class="sm">/system/files/media/file/2023/11/Reject-Site-Neutral-Payment-for-Lower-Standards-of-Infusion-Care.pdf</small></a><small class="sm"> </small><br><small class="sm"><sup>8</sup> </small><a class="ck-anchor" href="/system/files/media/file/2024/01/medicare-significantly-underpays-hospitals-for-cost-of-patient-care-infographic.pdf" id="/system/files/media/file/2024/01/medicare-significantly-underpays-hospitals-for-cost-of-patient-care-infographic.pdf"><small class="sm">/system/files/media/file/2024/01/medicare-significantly-underpays-hospitals-for-cost-of-patient-care-infographic.pdf</small></a><small class="sm"> </small><br><small class="sm"><sup>9</sup> </small><a class="ck-anchor" href="https://blog.turquoise.health/moving-into-2024-state-of-price-transparency/" id="https://blog.turquoise.health/moving-into-2024-state-of-price-transparency/"><small class="sm">https://blog.turquoise.health/moving-into-2024-state-of-price-transparency/</small></a><small class="sm"> </small></p> Tue, 30 Jan 2024 09:37:09 -0600 Making Healthcare More Affordable