The AAMC July 12 submitted a comment letter to CMS in response to a request for information to reduce regulatory burdens imposed by the Affordable Care Act (ACA). CMS is soliciting comments to create a more patient-focused health care system and address affordability, accessibility, quality, innovation, and empowerment. Specifically, CMS is requesting information about changes to existing regulations or guidance to empower patients and promote consumer choice of health plans and providers.
AAMC agrees that consumers must have access to high-quality, high-value healthcare providers, and addressing ways to make health insurance more affordable is one way to achieve this goal. However, in order to maintain robust individual and small group marketplaces, consumers must also have access to networks of providers that meet their care needs. The AAMC is concerned that changes aimed at strengthening the individual market while also attempting to reduce regulatory burden – specifically, relaxing the regulations surrounding network adequacy and essential community providers for qualified health plans (QHPs) – may actually limit consumer choice and restrict access to providers and, in addition, leave providers who treat these patients either underpaid or not paid at all.
AAMC highlighted the need for robust provider networks that include teaching hospitals and faculty physicians to promote consumer choice in the marketplaces. In addition, we recommended that CMS re-evaluate the need for inclusion of time and distance in network adequacy criteria in order to promote consumer choice of health insurance and providers. AAMC also urged CMS not to reduce standards for demonstrating a sufficient number and geographic distribution of essential community providers. Finally, the AAMC highlighted its support of moving from payment based on volume to payment based on value of health care services. To that end, the AAMC urged CMS to account for sociodemographic status (SDS) factors when evaluating health outcomes in order to ensure that all hospitals are assessed on an even playing field and to not penalize those hospitals that serve a disproportionate number of patients that are medically complex and of low sociodemographic status.