Last Friday, Community Catalyst submitted comments in response to a request for information from a group of Senators looking to improve transparency in health care. After a year of defending the Affordable Care Act and Medicaid from attacks that would have caused millions to lose access to care, it was a refreshing change of pace to focus on proactive solutions that can make navigating the health system easier for consumers.
That being said, we also know that transparency alone is not the solution to improving patients’ outcomes and experiences or reducing costs. In fact, only 7 percent of consumers’ out-of-pocket health care spending is on “shoppable” services, suggesting that the purchasing power of consumers has limited ability to drive affordability and quality of care. That’s why, in our comments, we asked the Senate to advance transparency efforts that will benefit consumers the most, while recognizing that improving health care for consumers will ultimately require much more than transparency. To that end, any efforts to improve transparency should:
- take into account the unique needs of different patient populations, including patients with complex health needs;
- empower consumers by improving their ability to access the highest quality care and select providers that fit their needs while protecting them from the financial burden of increased out-of-pocket costs; and
- happen in parallel with efforts to improve quality of care and access to meaningful and easy-to-understand quality data.
Although we recognize the limitations of efforts to improve transparency, there are a number of patient-friendly transparency ideas that could actually improve consumers’ experience at both the point of care and point of plan choice:
- Transparency in coverage and benefits at the point of plan choice and throughout the year. Consumers should be fully informed about how their coverage works and what their health care costs are so that they can make informed decisions. This information should be easily accessible and explained in a way that consumers can relate to, including common examples, interactive tools and plain-language descriptions. Transparency of plan information – including up-to-date and accurate formularies and provider networks should be available to both prospective and current enrollees. In addition, consumers should be protected from surprise medical bills that can add up to thousands of dollars.
- Transparency in provider billing and collections. Medical debt affects tens of millions of consumers. It is one of the most prevalent types of consumer debt, with one in five Americans being contacted by a debt collector over an unpaid health care bill. To help address the problem of medical debt and increase transparency, the ACA made important strides towards this goal by establishing requirements around fair, transparent billing for non-profit hospitals. But these protections don’t extend to other provider types. Congress should continue to require HHS, the Internal Revenue Service, and other federal agencies to improve consumer protections and increase fairness and transparency with regard to provider billing and collections.
- Transparency in prescription drug pricing. Because of the complexity of the pharmaceutical supply chain, consumers and purchasers are kept in the dark about what drives high drug costs and how to manage them. In order to better inform policymaking decisions and public debates, pharmaceutical manufacturers should be required to disclose a wide range of information related to drug pricing, investment in drug development, manufacturing and marketing to the public in a clear, straightforward and timely manner. In addition, formulary benefit design should promote transparency. To protect consumers from excessive out-of-pocket spending on life-saving medications, Congress should prohibit the use of coinsurance and cap monthly copayment at no more than $150 per drug per month.
- Transparency in new payment and delivery models. With the increase in integrated and risk-bearing delivery models, like Accountable Care Organizations, patients should be fully informed of if and how they are being assigned to a new model of care and beneficiaries have a right to know about any new financial incentives that may influence provider behavior and the care that is delivered. Beneficiaries also need to fully understand what they can expect from these models, and what their rights are under these models, as well as information about the grievance process.
- Transparency in the federal decision making process. Just as we believe consumers deserve access to clear and transparent information when it comes to their health coverage and care, consumers also deserve transparency around the federal policymaking processes that impact their care. Federal health care initiatives should be implemented in a transparent manner that includes opportunities for public input.
We’re glad that some members of Congress are thinking proactively about ways to improve the health system for consumers, but these proactive steps need to be part of a multi-pronged, patient-friendly approach that strives to improve care for all consumers.