A Return to the Dreaded Capitation?

A recent Wall Street Journal article discusses a new contract between Blue Cross Blue Shield of Massachusetts and the Caritas Christi Health Sytem based on a new approach to payments.  Under Massachusetts near-universal coverage, there has been a significant escalation of health care costs, and BCBS is making an effort to rein in that cost spiral.  It has begun entering in "alternative quality contracts" with networks of hospitals and physicians in Massachusetts  to replace the traditional fee-for-service payment system.

Under the new arrangements, Caritas, a system of hospitals and over 1000 employed or affiliated physicians, will be paid a fixed amount to provide all the care for 60,000 patients.  This is reminiscent of the 1990's capitation payments, a flat monthly payment per patient (known as a per member per month, or "PMPM", payment) assigned to the providers.  Under a capitation contract, providers could have higher revenues if less care was rendered, as the PMPM amount didn't vary with actual services provided.  Health care plans and providers were widely criticized for capitation payments, as it was perceived that this would result in withholding needed care or cherry picking only healthy patients.  By the end of the decade, most plans had eliminated capitation contracts and returned to fee-for-service arrangements.

In order to avoid the seeds of criticism, the BCBS methodology pays a monthly fee per patient, but also rewards providers with bonuses if they meet certain quality targets.  The goal is to refocus profit-potential from capitation's less care being provided to having better patient outcomes.  These new contracts are for hospital-physician networks, to encourage coordinated efforts.

The WSJ article suggests that today's information technology might make this goal of cost-saving and outcome improvement reachable.  To make this incentive system work, though, it will require that hospitals, primary care doctors and specialists collaborate to determine appropriateness of  care and a fair division of the payments.  This has been an unresolved problem for prior efforts to reform health care delivery and payment.  It may be easier in a unified system of hospitals and employed physicians, but it has proven to be a real dilemma in most networks of independent physicians.  I guess if it were easy, we would have health care reform twenty years ago.   

 

 

How Do They Compare? House Vs. Senate Health Care Proposals

If you're looking for some clarification on what the House and the Senate are bringing to the table in terms of health care reform, the New York Times provides an informative, click-through guide that will provide some insight.  With a bulleted, issue-by-issue comparison, the guide highlights some of the key differences between the House and Senate health care proposals, including insurance mandates, employee contributions and total coverage and cost.

Clarification of HITECH's Amendments to HIPAA's Civil Monetary Penalties

Recognizing the confusion surrounding HITECH's significant amendments to HIPAA's Enforcement Rule, the Department of Health and Human Services ("HHS") published the Interim Final Rule on HIPAA Enforcement ("Interim Final Rule") on October 30th.  The Interim Final Rule seeks to clarify the revised civil monetary penalty scheme established in HITECH, noting that many covered entities "may be unaware they are currently subject to significantly greater penalties for violations of the HIPAA rules."  Indeed - the increase in the maximum aggregate penalties from $25,000 to $1,500,000 is big news for all covered entities (and now business associates too).  HHS felt that this information was so important, it waived the notice and comment period and proceeded straight to the interim final rule, which becomes effective on November 30, 2009.     

 

 

And Yet Another Delay....Red Flags Rule Enforcement Date Pushed Back Until June 2010

The Federal Trade Commission (FTC) announced that it will delay the enforcement of its Red Flags Rule for a fourth time, extending the start date to June 1, 2010.  The FTC previously delayed enforcement until November 1, 2009, but decided on the further extension due to a request from members of Congress.

The Red Flags Rule addresses identity theft and requires certain "creditors" to develop identity theft prevention programs.  You can learn about the specific requirements of the Red Flags Rule in a prior DGS post.