We write to comment on the October 2, 2013 proposal to amend 42 C.F.R. §121.13 with respect to compensation for donors of peripheral bone marrow stem cells. Because the notice of proposed rulemaking fails to offer an adequate justification for the proposed regulation, which would likely reduce the availability of life-saving bone marrow transplants, we respectfully recommend that the proposal be withdrawn.
In North Carolina, for example, the state legislature recently passed a law requiring hospitals to make several kinds of price information available, including the average amount they settle for when billing uninsured patients, and the average amount they charge to the largest insurers in the state. Massachusetts and New Hampshire have passed price transparency legislation of their own, legislation that was given a grade of A by The Healthcare Incentives Improvement Institute. I expect more states to pass similar legislation, meaning companies like OpsCost will soon have a larger number of numbers to plug into their user-friendly websites.
U.S. GAO – Health Care Fraud and Abuse Control Program: Indicators Provide Information on Program Accomplishments, but Assessing Program Effectiveness is DifficultOctober 30, 2013
according to the fiscal year 2012 HCFAC report, the return-on-investment–the amount of money returned to the government as a result of HCFAC activities compared with the funding appropriated to conduct those activities–has increased from $4.90 returned for every $1.00 invested for fiscal years 2006-2008 to $7.90 returned for every $1.00 invested for fiscal years 2010-2012.
Several factors contribute to a lack of information about the effectiveness of HCFAC activities in reducing health care fraud and abuse. The indicators agencies use to track HCFAC activities provide information on the outputs or accomplishments of HCFAC activities, not on the effectiveness of the activities in actually reducing fraud and abuse. For several reasons, assessing the impact of the program is challenging. For example, it is difficult to isolate the effect that HCFAC activities, as opposed to other efforts such as changes to the Medicare provider enrollment process, may have in reducing health care fraud and abuse. It is also difficult to estimate a health care fraud baseline–a measure of the extent of fraud–that is needed to be able to track whether the amount of fraud has changed over time as a result of HCFAC or other efforts.
It starts with affordability. When patients lack health insurance, it is hard to make appointments at primary care clinics which, like most healthcare practitioners, initiate their evaluation of patients with a procedure sarcastically referred to as a “wallet biopsy.” If you want an appointment to see a primary care physician for an earache, the appointment clerk is going to ask you about your insurance. If you don’t have coverage, the clerk is usually going to remind you that you will have to pay the doctor’s fee out-of-pocket, before receiving care. By contrast, if you show up in an emergency room with that same earache, the clinicians there will be obligated to evaluate you and make sure you don’t have an emergent condition. In other words, you’re going to be seen.
In her 2010 book The Immortal Life of Henrietta Lacks, Rebecca Skloot told the story of Henrietta Lacks and the cell lines derived from her cervical tumor biospecimen (cell lines known to scientists simply as “HeLa cells”). To make a long story short, in 1951 physicians at Johns Hopkins Hospital took a biopsy from a patient, Henrietta Lacks, and from that biospecimen developed the first human cancer cell line. The biospecimen was taken without Lacks’ knowledge or informed consent. No laws were broken in the creation of the HeLa cell lines that are now recognized (pdf) as “the most widely used human cell line in the world.” She died in 1951, and it was reportedly not until 1973 that her family learned about the HeLa cells (two years after Henrietta Lacks’ name was published as the source of HeLa cells in a scientific journal). As the table below shows, this incident occurred long before the adoption of regulations and ethical guidelines for biomedical research that, today, generally require researchers to obtain voluntary, informed consent from individuals before performing biomedical experiments.
The Department of Health and Human Services (HHS), including the Centers for Medicare & Medicaid Services (CMS), have demonstrated a strong commitment to greater data transparency in recent years.
The Health Data Initiative was launched by HHS in 2010 to promote transparent, innovative, and safe data use. CMS is also engaged with a wide range of public, non-profit, and private sector stakeholders to foster the availability and use of health care data to drive innovations that improve health and health care.
Since 2010, CMS has released an unprecedented amount of aggregated data in machine-readable form. These data range from previously unpublished statistics on Medicare spending, utilization, and quality at the state, hospital referral region, and county level, to detailed information on the quality performance of hospitals, nursing homes, and other providers. In May 2013, CMS released information on the average charges for the 100 most common inpatient services at more than 3,000 hospitals nationwide, followed in June with the release of average charges for 30 selected outpatient procedures.
On May 31, 2013, a Florida federal district court lifted a permanent injunction originally issued in 1979 that prohibited the Department of Health, Education, and Welfare (as HHS was then known) from disclosing annual Medicare reimbursement payments to individual physicians or in a manner that could identify individual physicians.
In light of this recent legal development and our ongoing commitment to greater transparency in the health care system, CMS seeks public input on the most appropriate policies with respect to disclosure of individual physician payment data.
Though the agreement, which was announced Wednesday, is a milestone in the saga of Ms. Lacks, it also draws attention to a lack of policies to balance the benefits of studying genomes with the risks to the privacy of people whose genomes are studied — as well as their relatives.
As the journalist Rebecca Skloot recounted in her 2010 best-seller, “The Immortal Life of Henrietta Lacks,” it was not until 1973, when a scientist called to ask for blood samples to study the genes her children had inherited from her, that Ms. Lacks’s family learned that their mother’s cells were, in effect, scattered across the planet.
Financially speaking, patients soon will find visits to North Carolina hospitals less painful and mystifying.
Under laws passed by the General Assembly, they’ll get more protection from aggressive bill-collection practices.
Hospitals will be prohibited from putting liens on the houses of some patients, and will have to give written notice before sending accounts to a collection agency.
Patients will also find it easier to comparison shop. Starting next June, hospitals must post prices for common procedures, as well as their charity care policies.
And they’ll have to put their bills in plain, easy-to-understand language without obscure codes and medical jargon.
Conditions in North Carolina nursing homes are better today than they were in 2009 but still just slightly above average compared with those in other states, according to a survey commissioned by the U.S. Centers for Medicare &Medicaid Services.
U.S. GAO – Medicare: Action Needed to Address Higher Use of Anatomic Pathology Services by Providers Who Self-ReferJuly 15, 2013
Self-referred anatomic pathology services increased at a faster rate than non-self-referred services from 2004 to 2010. During this period, the number of self-referred anatomic pathology services more than doubled, growing from 1.06 million services to about 2.26 million services, while non-self-referred services grew about 38 percent, from about 5.64 million services to about 7.77 million services. Similarly, the growth rate of expenditures for self-referred anatomic pathology services was higher than for non-self-referred services. Three provider specialties–dermatology, gastroenterology, and urology–accounted for 90 percent of referrals for self-referred anatomic pathology services in 2010.