March 22, 2017: MGMA letter commenting on the American Health Care Act of 2017

March 22, 2017

The Honorable Paul Ryan
Speaker
House of Representatives
Washington D.C. 20515

The Honorable Nancy Pelosi
Minority Leader
House of Representatives
Washington D.C. 20510

Dear Speaker Ryan and Minority Leader Pelosi:

The Medical Group Management Association (MGMA) believes there is significant potential to improve the Affordable Care Act (ACA); at this stage, however, it is difficult to see how the American Health Care Act (AHCA) does so in a manner consistent with our Association’s core healthcare reform principles. As Congress considers legislation that impacts the policies or financial underpinnings of the ACA, it should above all, minimize disruptions to the nation’s healthcare delivery and payment system.

MGMA and its 50 state affiliates comprise more than 33,000 administrators and executives in 18,000 healthcare organizations in which 385,000 physicians practice. MGMA represents physician groups of all size, types, structures and specialties. As the leading association for medical practice administrators and executives for 90 years, MGMA produced a set of healthcare reform principles, including:

• Ensure continuity of patient care and meaningful coverage. Affordable health insurance that allows for continuity of patient care and coverage should be at the core of any healthcare reform. Our healthcare system must enhance the ability of medical group practices to provide high-quality, costeffective care to the millions of patients they serve.
• Patient choice, transparency, and appropriate provider reimbursement. The proliferation of narrow, often opaque provider networks coupled with reduced payments for participating providers is counter to an open and effective healthcare system. Health plans should be subject to the highest levels of state and federal accountability for fair business practices and required to provide standardized language to explain insurance coverage to patients. Any reform should ensure patients have access to the physicians and medical group practices of their choice and promote appropriate reimbursement for care provided.
• Reduce costly administrative and regulatory burdens that detract from patient care. To ensure the viability of our healthcare system, we must make a national commitment to administrative simplification, reducing regulatory burden, and promoting efficient automated processes.
• Leverage the group practice model to advance physician led reforms. Medical group practices represent a unique and effective care delivery approach that promotes care coordination and efficient, high-quality patient care. Excessive costs associated with care delivered in high-cost facilities drive up healthcare expenses for all. To achieve true system savings, patients should be incentivized to use the most appropriate, cost-effective clinical setting, such as medical group practices. Any reform should leverage the proven group practice model in developing new payment and care delivery systems.
• Enact medical liability reform. Liability reform is critical to the healthcare system. Defensive medicine and liability insurance premiums are significant drivers of healthcare costs. Legislation that seeks to improve healthcare must include meaningful liability reform.
• Minimize disruption when implementing reform. It is imperative that implementation of any health system reforms allow ample time for the healthcare industry to implement necessary changes to business and care delivery processes to minimize costly disruptions to patients and medical group practices.

We understand the AHCA is being positioned as a first step in the process to reform our healthcare system; however, we have concerns. For example, two of the most challenging issues presented to medical groups from the ACA were the resultant proliferation of high deductible insurance products and narrow health plan provider networks. Given recent CBO projections, even factoring in a reasonable margin of error, it is not clear how the AHCA would address these two major shortcomings in the context of tens of millions of Americans potentially becoming uninsured. A significant scaling back of overall government support, irrespective of modifications to delivery mechanisms as outlined in the AHCA, will likely result in one or both of the following outcomes: exacerbation of patient coverage issues and further reductions to providers already reimbursed at or below cost for the care they provide, especially to the most vulnerable patients in the country.

Finally, but no less important from a business standpoint, there is an incredible opportunity for Congress to build upon momentum created through the successful repeal of the SGR and support businessfriendly policies to reduce the excessive administrative burden faced by medical group practices in our healthcare system today. With approximately 15% of healthcare expenditures going toward administrative costs because of non-standardization processes and delivery system inefficiencies, much can still be done.

Understanding there are limitations on what may be considered during the budget reconciliation process, we urge Congress and the Administration to reveal a complete picture of the full regulatory and legislative elements of this reform package so MGMA and other stakeholders can continue to provide constructive input on the plan in its entirety. Transparency and open discussion are critical to ensuring any healthcare reform legislation meets the principles outlined by MGMA in this letter.

As the voice for the country’s medical group practices, MGMA looks forward to a productive dialogue and remains committed to promoting policies that enhance the ability of our members to provide high-quality, cost-effective care to the millions of patients they serve. Should you have any questions, please contact Anders Gilberg, Senior Vice President, Government Affairs at agilberg@mgma.org or 202-293-3450.

Sincerely,
Halee Fischer-Wright, MD, MMM, FAAP, CMPE President and CEO