Later this week the state’s Health Policy Commission (HPC) will be holding a public hearing on proposed regulations for the registration of provider organizations. The hearing, scheduled for February 12, 2014 at 1 pm, will likely generate comments from providers and provider organizations such as Atrius Health that will be affected by the regulations and some of the new requirements of the HPC. Written comments are due to the HPC on April 11, 2014 by noon.
Under the proposed regulations, provider or provider organizations will be required to register if they have at least $25 million in annual net patient service revenue from private carriers and third-party administrators in the prior fiscal year; and a patient panel of more than 15,000 over the past 36-month period. The proposed regulations define a “provider” as any person or entity qualified in Massachusetts to provide health care services, and a “provider organization” includes any entity or organized group in the business of health care delivery or management that represents one or more health care providers in contracting with private payers or third-party administrators (such as physician organizations, physician-hospital organizations, independent practice associations, provider networks, and accountable care organizations.) The regulations also require Risk-Bearing Provider Organizations (RBPOs) certified by the Division of Insurance (DOI) under proposed regulations (that have yet to be finalized) to register with the HPC.
Much of the proposed regulations come directly from Chapter 224 of the Acts of 2012 and we recognize the HPC is bound by these requirements (such as information on ownership, governance, funds flow, revenue and number of full-time equivalent health care professionals.) However there are certain provisions in the proposed regulations that go beyond the current statutory requirements that we believe will impose additional administrative burdens and costs for providers and should be re-considered by the HPC. For example, it will be very labor intensive to provide detailed information about health care professionals including individual names and addresses of health care practitioners, national provider identifiers (NPI) and employment status (contracted or employed, FTE status. In addition, given there is a constant change as providers join or leave practices, information will be quickly outdated within a short period of time anyway.
Given the myriad of reporting requirements already faced by providers and provider organizations under Chapter 224, we strongly suggest the HPC collect only baseline information that is absolutely required under the existing law for the first several years to minimize administrative burdens and cost. The HPC should work with its other partner agencies, most notably the Center for Health Information and Analysis and DOI, to identify existing data that is already being collected that would be helpful to its work.
Finally, as part of the rollout of the new regulations, the HPC will release a “Data Submission Manual” detailing specific requirements prior to the release of the proposed regulations. We applaud the HPC for its commitment to actively engage stakeholders in the development of this manual in the coming months. Atrius Health is committed to being an active participant in these and other related discussions of the HPC in order to move forward our community goals of making healthcare higher in quality and more affordable.