Part D and Hospice Rules Mucking Up Beneficiaries' Last Days

Last week the Centers for Medicare and Medicaid Services (CMS) met with 30 hospice & healthcare organizations about suspending a new rule intended to avoid duplicate payments for hospice medications. This is a very big deal and the new rule is mucking up many beneficiaries' last days. The National Hospice and Palliative Care Organization described the meeting as "an important first step at righting the wrongs being faced by dying Medicare patients."

Previously, hospice (under Medicare Part A) paid only for the drugs that patients needed for palliation and management of the terminal illness and related conditions, and Medicare Part D covered drugs for hospice patients' unrelated conditions. Under the new rule, CMS requires a beneficiary level prior authorization process for all hospice and Part D providers to determine responsibility of drug coverage, and hospice must cover medications related only  to the hospice diagnosis.

CMS' expectations are unrealistic. Putting prior authorizations on everything adversely impacts beneficiary access to drug therapies and causes agonizing delays at the point of service. Consider this: first, it has to be determined if the drug in question is covered under Part A or D. If Part A, then you have to figure out if it's even covered under the hospice formulary and beneficiary refuses to try formulary equivalent first or drug is not reasonable or necessary  per the hospice provider if not and the beneficiary wants the drug, it will be self-pay. If it's neither Part A nor D, then the beneficiary must self-pay. If covered under Part D and the prescriber is not hospice affiliated, the sponsor has to jump through hoops, including what to do if the prescriber is unable or unwilling to coordinate with the hospice provider.Then, if the drug has prior authorization on Part D it would have to satisfy those requirements. Plans have to be able to accept and save proactive determinations from hospice. It's an administrative nightmare. For 2014 only, CMS is universally allowing Plans to treat hospice coverage determinations as exceptions. That in and of itself shows that they are not sure how best to handle this mess.

With end-stage patients (the only kind you get in hospice), it is often difficult to discern which drugs are used for symptom management and what drugs are really for chronic conditions that if in hospice should not be treated, such as diabetes or hypertension meds. The hospice industry has reported widespread confusion and disputes that have made it harder for patients to get their drugs.

Seventy senators signed onto a letter circulated by Sens. Jay Rockefeller (D-WV) and Pat Roberts (R-KS), calling for CMS to suspend the rule. "We ask that CMS immediately suspend the Guidance and begin a process to develop an alternative approach which will ensure both that the right individual or entity pays for the hospice patient's medications and that the patient get the medication that he or she requires without interruption," they write.

We agree and hope CMS goes back to the drawing board on this rule. Calm and freedom from pain should define a beneficiary's last days, not administrative hoops and preauthorizations.

 

 

Resources

If you've just submitted your HEDIS data, now is the time to analyze that data for gaps and identify interventions for your health plans, providers and members. On July 17 join John Gorman, Executive Chairman at GHG, Jane Scott , Senior Vice President of Clinical Services and Anita McCreavy, Senior Consultant, for a webinar on HEDIS reporting, the new measures and what's next. Register now >>

The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult — to say nothing of actually managing to them. Contact us today to learn how we can help >>


Further Evidence That PBMs are Failing on Government Programs

At CMS' oversight and enforcement conference last week Jonathan Blanar, the agency's Deputy Director of Compliance Enforcement, presented the following slide. In this slide, you will see actions CMS has imposed against Medicare health plans in the last two years, and for what reasons. It's further evidence that pharmacy benefit managers (PBMs) are failing Medicare beneficiaries and the plans enrolling them.

 

 

PBMs have a big hand in the first category, coverage determinations, though they're not entirely culpable.  What's maddening about that tally is the fact that appeals and grievances rules in Medicare haven't changed much in the 17 years since they were first issued, and PBMs and plans are still screwing it up.  To CMS, appeals are the most important consumer protection at the point of service, so they dish those findings out regularly.

It's the second category, formulary administration, that's most disturbing.  The numbers speak for themselves.  But Blanar added this color, the most frequent findings, which included the following and are a damning indictment of PBMs as the Keystone Kops of government programs:

 

  • Unapproved quantity limits
  • Unapproved utilization management practices
  • Failure to properly administer the CMS transition policy
  • Improperly effectuating a prior authorization or exception request
  • Failure to provide a transition supply of a non-formulary medication
All these functions are WHAT PBMs DO and should be de rigueur in Medicare Part D by now. The fact that PBMs are still messing these functions up, and dragging down their plan sponsors with them, should be serious reason for concern from the compliance officer to the boardroom.

 

Resources

If you've just submitted your HEDIS data, now is the time to analyze that data for gaps and identify interventions for your health plans, providers and members. On July 17 join John Gorman, Executive Chairman at GHG, Jane Scott , Senior Vice President of Clinical Services and Anita McCreavy, Senior Consultant, for a webinar on HEDIS reporting, the new measures and what's next. Register now >>

The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult — to say nothing of actually managing to them. Contact us today to learn how we can help >>


Most, if Not All, States Will Be on the Federal Exchange by 2020

Correction: June 20, 2014

An earlier version of this article misidentified the state of Washington as preparing to enter into the Federal Exchange. Though the state of Washington is having trouble with its enrollment website, Washington Health Benefit officials have clarified that Washington state has no intention of becoming part of the federal marketplace.

 

As ObamaCare launched last fall you'll recall 16 states started their own exchanges, 7 were State/Federal partnerships (effectively operated by the Federal exchange for most functions), and 27 states were supported purely by the Federal Exchange.

 

Ironically, most of these were in red states where Congressional delegations and governors and state legislatures wailed about a "Federal takeover of healthcare," and that's exactly what they got by their inaction. We knew at least 3 would have no choice but to drop out after the first year and go Federal. As preparations continue for ObamaCare's second enrollment period in October, it's now clear at least half of the state-based exchanges are going Federal in 2015.

I'll say it: I think most states, if not all, will be on the Federal exchange by the end of the decade.  The only holdouts will be states where the politics necessitate it, like Kentucky's KYNect, home of Senate Minority Leader Mitch McConnell (R-KY). KYNect has been wildly successful, signing up over 420,000 Kentuckians, many gaining health insurance for the first time in their lives, and it's giving McConnell fits in his midterm reelection bid.

The technology to run an exchange at state and Federal is duplicative, basically the same black box web-commerce architecture from over a decade ago, made wildly complex by the many state and Federal agencies involved in eligibility and enrollment. In the last several months we've seen multiple states crash and burn trying to stand it up, just as healthcare.gov did last fall.  Oregon is preparing to sue Oracle for its botched system.  Maryland's goat rodeo of an exchange launch has become a wedge issue in the governor's race. Now, Politico reports that Washington state is dealing with "back end" problems on its enrollment website, and the ObamaCare launch actually went relatively well there.

Then there's the issue of cost. The Affordable Care Act requires state-based exchanges to be self-sufficient in 2015. Those that went their own way had the buildout — or meltdown — largely paid for with Federal funds in 2011-2012. It was a vendor's Full Employment Act, with extremely mixed results. Next year's a whole different matter. State-based exchanges costs hundreds of millions of dollars annually to operate, and that won't last long in cash-strapped legislatures. The only ones left standing at the end of the decade may be Kentucky — and only as a middle finger to McConnell, as long as he may be in office — and California. Because it's California.

So for those health plans operating in states already under the Federal exchange: steady as she goes and stay current as pregame festivities begin for the second open enrollment period. If you're operating in a state doing it's own thing that's not KY or CA, you may want to consider re-speccing your systems for Federal functionality. It's only a matter of time in my opinion.

 

Resources

The launch of the Health Insurance Exchanges is the most challenging implementation in our industry's history with a patchwork of eligibility, new systems and numerous regulations. GHG can help, find out how >>


Tuesday Night's Primary Elections Were Huge. Here's What They Mean for Our Industry.

House Majority Leader, Eric Cantor (R-VA) is toast.  Trounced in his Richmond district by a nobody Tea Bagger Tuesday night. Cantor gave up his leadership position yesterday. Depending on where you sit politically, either the unthinkable or the inevitable happened.  In fact, a Majority Leader hasn't lost incumbency since the office was created in 1899.   "The defeat of the second-ranking Republican in the House by an ill-funded, little-known tea party-backed candidate ranks as the biggest congressional upset in modern memory and will immediately generate a series of political and policy-related shock waves in Washington," wrote Chris Cilizza of WaPo.

What it means for our industry is that legislatively speaking, President Obama's second term is already over.  The House will seize up like a bag of concrete in a toilet.  The most unproductive Congress in history is about to continue and worsen that record as an epic Republican leadership battle ensues.

That means Obama is left chasing his agenda through administrative action, Executive Orders, regulations and enforcement.  With brand-new and surprisingly popular HHS Secretary Sylvia Mathews Burwell on the job, expect her department to flex its muscles in ways we haven't seen, especially given the number of oversight hearings she's about to be subjected to:

  • There will be tough new rules for all government-sponsored health programs: Medicare, Medicaid and implementation of the Affordable Care Act.  The contentious new Part D rules are just the beginning.
  • There will be increasing activism in network adequacy and rate reviews of insurers in Medicare Advantage, Part D and the exchanges;
  • CMS will take a hard line on Medicare plans lagging in Star ratings and/or compliance records.  The second term of a Democratic administration is always when scores are settled; the renewed Congressional scrutiny on our favorite agency will make the paper tiger grow some claws;
  • CMS and the HHS Inspector General (IG) will finally put the pedal down on dreaded RADV audits with the promise of hundreds of millions in recoveries.
  • With wingnuts like House Oversight Chairman Darryl Issa (R-CA) salivating for domestic Benghazis, the HHS IG will likely deliver a few surprises of its own.

Every time there's a major electoral event in Washington like this, elected and appointed officials alike will usually settle back on the motherhood and apple pie of health care politics: kicking the crap out of the insurance industry and other monied interests like pharmaceutical manufacturers and PBMs.  If you're not wearing them already, it's time to pull on the kevlar boxers and the asbestos Spanx.


Aetna Offers a Playbook for Evolution in the Golden Age of Government Programs

Ralph Giacobbe of Credit Suisse got another terrific "get" hosting Aetna's management team for an insightful discussion last week.  I found the takeaways offer a playbook for how to adapt and evolve in the new Golden Age of government-sponsored health programs:

Watch Your Wallet:  Aetna assumed an accelerating cost trend in 2014 of 6-7%.  The company noted that underlying cost trends remain generally muted and that overall drug spend is within expected ranges. The company's informatics and medical economics function tracks a wide range of data indicators for early warning of cost acceleration, and had nothing unusual to report.

Put the Pedal Down on the Government Platform: Aetna acquired Coventry for the purpose of having a seasoned platform for government business, so integrating the company remains a top priority for Aetna in 2014. You may recall Aetna called Fran Soistman, a legendary founder of Coventry and a battle-hardened veteran of Medicare Advantage and Part D, out of retirement to run its government business unit.  He's been making huge progress in leveraging the company he built within Aetna. For instance, Aetna ranked #1 in price in 6 of 7 ObamaCare exchange regions in Florida, largely because of Coventry's footprint there. Aetna continues to expect $200M in synergies and $0.50 of accumulated accretion in 2014, and $400M in synergies and $0.90 of total accretion in 2015 from the Coventry acquisition.

Invest in Medicare Advantage Stars: Aetna invested heavily in Star ratings improvement the last two years, and now averages 4+ Stars.  As a result, the bonus payment and favorable rebates it gets allowed the company to maintain competitive premiums and benefit designs for 2015 in the face of a 3-3.5% revenue headwind. The company remains positive on its competitive position, and expects to grow membership next year.

ObamaCare Exchanges in 2014-2015: This year Aetna is participating in 17 states and has 570,000 paid public exchange members, with management expecting to have 450,000 exchange lives by year end due to churn. The company booked some reinsurance in 1Q and now believes it may get the data to begin to factor in risk adjustment. Risk corridor remains more difficult to estimate and will evolve as experience matures. Aetna's exposure in the exchange market is limited to 5% of projected 2014 revenues and its guidance incorporates a modest drag on earnings. The company doesn't expect to expand its footprint in the ObamaCare exchanges in 2015 until it has a clearer picture on costs and the competitive landscape.  Management suggested it would seek average high-single digit pricing increases for 2015 on the exchange -- and there's some comfort there as an early indicator that trends so far in the exchanges are not as crazy as the rate hikes of 15%-20% seen from other plans.

Aetna's perspectives, when considered against the backdrop of United's outlook for the next couple years, paints a picture of a rapidly-expanding government book of business that is gaining on its longtime commercial market dominance.  It's a portrait of evolution in the Golden Age of publicly-sponsored health care.

 

Resources

Listen as John Gorman, Executive Chairman at Gorman Health Group and Josh Raskin, Managing Director at Barclays, discuss the recently released Stars data, and the seismic impact of the 8.5 billion quality demonstration. Access the podcast here >>

In this recorded webinar, John Gorman explores what "member centricity" means in today's government health care industry, at a time when consumerism is defining our relationships with members more than ever, and with CMS elevating quality improvement to game-changing levels. Download the webinar >>


The Status of Medicaid Expansion, and Why It Will Keep Getting Better

Medicaid is already the largest insurer on the planet, and the Affordable Care Act (ACA) is driving enrollment faster than anyone imagined.  But there are headwinds in covering more Americans through Medicaid, some political, some operational.  Here's why it will continue to improve and drive expanded coverage for the uninsured -- and why all insurers need to participate to remain relevant to the new American healthcare landscape.

Twenty-six states have expanded eligibility under the ACA to everyone with incomes under 138% of the federal poverty level, or about $16,100 for an individual. April's Medicaid enrollment report from CMS showed a year-over-year increase of over 6 million, a 10.3% increase.  Much of this is due to the "woodwork effect" -- folks heard about ObamaCare, applied through the exchanges, and found they were Medicaid eligible.  It doesn't count nearly a million Americans who gained coverage under the ACA's "early option" or a waiver.

Predictably, enrollment has grown much faster in Medicaid expansion states (mostly Blue) than in states that have not expanded Medicaid (all Red): 15.3% in expansion states, but only 3.3% in non-expansion states.

 

Nine out of 24 states that had Medicaid expansions in effect in April experienced an enrollment increase of 25%.  Ironically, many states with the largest Medicaid enrollment growth also had the most dysfunctional exchanges: Oregon at 49.4%; Nevada at 41.1%, and Maryland, at 29.7% growth.

The problem has been that between exchange dysfunction, weak infrastructure, and a culture in many state Medicaid agencies of creating barriers to enrollment rather than the ACA's policy of "no wrong door", more than 1.7 million are still waiting for their applications to be processed — with some stuck in limbo for as long as eight months. The scope of the issue varies widely: California accounts for 900,000 applications pending as of early June; Illinois has 283,000 cases pending, while New York has no backlog at all. All three states have implemented the ACA's expansion of Medicaid.  Even some big Red states that chose not to expand have enrollment pileups, including North Carolina (170,000 applications pending), Georgia (100,000), and South Carolina (62,000).

Matt Salo, executive director of the National Association of Medicaid Directors, thinks the worst is over. He said the computerized handoffs from the federal exchange are occurring more quickly and states are getting more data to approve or deny applicants.  "I don't want to say it's been solved," he said, "but it's definitely getting a lot better."  One measure: Publicly-traded health plan Medicaid revenue grew 19% in the first quarter of 2014, demonstrating the enormous economic opportunity from the expansion and the woodwork effect.

So if the backlog is largely resolved by the next open enrollment period this fall, the next big question is what about the 24 holdout Red states, the ones whose governors like Rick Perry (TX) and Bobby Jindal (LA) seem hell-bent on throwing a middle finger at the White House while thousands of their constituents literally die because of inaction.  Speculation is that a growing number of Red states will fold and take the Medicaid expansion money -- but not until after the midterm elections.  Here's why:

  • Funding:  the Feds are funding 100% of Medicaid expansion through 2016, scaling down to 90% in 2020+. While the initial ACA backlash may have provided cover for states not to expand, it will be increasingly difficult to continue to defend not taking the federal money to insure a significant population group.  Remember, Red states have the highest rates of uninsurance per capita, largely due to their historically stingy Medicaid programs.
  • Access: most states that choose not to expand created a significant coverage gap. This happens because subsidies on the exchange are available from 100%-400% of the Federal poverty limit, but not below that, leaving a low-income population paying significantly more for healthcare coverage.
  • "You're Still Paying for It": The ACA funds Medicaid expansion largely from tax revenue. States like Texas and Florida are among the highest contributors to general tax revenue and have the highest number of uninsured population.  They are helping to fund Medicaid expansion for other states via higher income taxes, yet not receiving any of the benefits for their own population.  Medicaid accounted for about two-thirds of all federal funding to states in 2014, up from 43 percent two years ago.
  • Hospitals: hospitals traded in insufficient DSH funding and bad debt for Medicaid or exchange coverage in the ACA.  Hospitals in Red states that didn't expand Medicaid are now reporting they can't even issue bonds for capital projects, and are dying on the vine as the DSH funds are taken away without a substitute.  Considering hospitals are often the largest employers in their communities, and especially in rural Red states, their lobbying might is expected to break anti-ObamaCare partisanship after the elections are over.

I'm not as optimistic as some on Wall Street that all RedGovs will fold in the face of these arguments, but suspect that several more will as we head into 2015. And given the central and growing role Medicaid plays in healthcare financing, health insurers are awakening to the fact that if they're not in it, they won't be around long.

 

Resources

Medicaid health plans must be able to navigate through State and Federal regulations and work well with State agencies. GHG can help, find out how >>


Obama Administration Puts Executive Focus on -- Surprise! -- Execution

In Washington we say that where a President puts his prize staffers is the best indicator of his priorities.  That being the case, two of POTUS' recent staffing moves paint a picture: Obama's #1 domestic priority is smoothing out ObamaCare before the next enrollment period this fall and solidifying the experience of the millions who gained coverage this year.

In the surprise of the year so far, it appears that Sylvia Mathews Burwell will cruise to confirmation as Secretary of Health and Human Services as early as this week.  Burwell is a longtime Obama confidant from the White House Office of Management and Budget and known as a strong manager of minutiae.  Like Mark McClellan did as CMS Administrator in the Bush Administration for the launch of Medicare Part D, she is a skilled bureaucrat with a mind for process, and with her budget background, certainly knows which cushions to find coins under.  As a veteran administrator, her job is high cover and finding the money her department needs to see the ObamaCare launch through as appropriations play out on the Hill.

Over the weekend, the White House elevated longtime aide Kristie Canegallo to the new position of deputy chief of staff for policy implementation, a role that will include keeping tabs on the ACA. The move, which coincides with the expected departure of healthcare adviser Phil Schiliro (a legislative wizard but not an operator), highlights the administration's intent to maintain focus on ObamaCare implementation after last fall's goat rodeo of a launch.  Her task will be hovering over Burwell and CMS Administrator Marilyn Tavenner and whipping the process along.

We know the biggest vulnerabilities that remain for ObamaCare are fixing the back end of CMS' systems that interact with insurers on their membership coming through the health insurance exchanges -- this will be Canegallo's focus --  and securing funding for the "3 R's" -- risk adjustment, reinsurance, and risk corridors, which will be Burwell's job.   Due to a drafting error in the ACA, nobody identified funding for exchange risk corridors; on Friday in the final exchange rule, HHS clarified that if risk corridor funds are insufficient the government will be required to step in and make issuers whole, and would find that money elsewhere in HHS if needed.  Nobody better for that than the former budget chief.

The challenge for these two exceptional women -- and even for Tavenner, a former hospital administrator -- is that none are particularly well-known or regarded in the insurance industry -- their partners in this next phase of implementation and wrinkle-smoothing. They will need to build that trust in a charged environment of preparing for the next open enrollment and possibly a Republican takeover of the Senate. Expect to see this triumvirate doing some serious outreach in the weeks and months ahead, and many White House meetings for AHIP's Karen Ignani and other industry reps.

Resources

Exchange enrollment is a multi-pronged strategy with member outreach and connection embedded within. Driving clinical and quality outcomes is contingent on financial alignment and market segment management. Visit our website to learn how GHG can help you develop your strategy.

GHG's Part D services are designed with your staff in mind, ensuring that with a mix of counsel and DIY tools your staff will have access to actionable information — faster. Contact us to learn more >>


What's Gained and Lost with an HHS Secretary Burwell

My old Clinton Administration colleague Sylvia Mathews Burwell sailed through a confirmation hearing last week.  What was expected to result in serious anti-ObamaCare fireworks and soundbite fodder for midterm campaigns ended with a whimper.  Her second confirmation hearing was yesterday, and it's a "Washington dog isn't barking" story.  It's now looking like she'll cruise through and we'll have an unexpectedly rapid successor to the embattled Kathleen Sebelius.

Mathews is unquestionably qualified for the job, but there are both positives and negatives of her succeeding the former Governor and Insurance Commissioner of Kansas as Secretary of Health and Human Services at the most critical juncture since Medicare and Medicaid were launched in the 60's.

Here's what's gained: bipartisan support.  Sebelius had become the face of last fall's ObamaCare meltdown and needed her own parking spot on the Hill for all the oversight hearings she had to endure. The GOP majority in the House had especially come to revile her, but Mathews is known on the Hill as a skilled technocrat with none of Sebelius' baggage, quiet, non-ideological, and effective.  It also helps that with the 7 million enrollee target easily met in the first ObamaCare open enrollment period and at a lower cost than expected, Republicans are turning away from their "repeal and replace" mantra of the last 4 years.

Mathews' proven management skills are also critically important as ObamaCare sails into Year 2. The initative's turnaround this winter was nothing short of incredible, but there's still ample opportunity for health insurers to cause a crackup with the less-visible "back end" problems that persist. Details matter now more than ever.  Remember Mark McClellan's impact on Medicare Part D.  A massive implementation of government-sponsored insurance needs an operator to see it through.

But here's what's lost: Burwell, locked in the bowels of the Office of Management and Budget for much of her career, enjoys none of the relationships with governors, state Medicaid directors, insurance commissioners or insurance executives Sebelius does, especially those in hostile red states where coverage expansion is needed most.  And that could hurt post-midterm chances of getting RedGovs to roll over on the Affordable Care Act's Medicaid expansion and hostile insurance commissioners like Georgia's to back off.  She will need to build trust as the face of ObamaCare with politicians in the deep south and west.  She will also need a "meet-and-greet" tour of insurance executives, and must demonstrate her ability to hear their concerns and implement fixes quickly in CMS in the runup to open enrollment Round Two.

This isn't to say Burwell will completely avoid controversy and that the Health Secretary's impossible job got much easier.  She should continue to pull on her asbestos Spanx every time she sets foot outside her new office in this political environment.  But it will give her some breathing room to hit the job hard, get some wins early, and build the trust that's necessary to see ObamaCare through from partisan lightning-rod to established and popular entitlement program.


Follow the Leader: United Health Group's Outlook on Government Health Programs

Ralph Giacobbe at Credit Suisse is a leading health industry analyst and is doing the best work of his career.  Today he produced a fantastic recap of his discussion with United Health Group CEO Steve Hemsley and several of his top executives.  It included some fascinating insights into the market leader's strategy for government health programs:

â–      2015 Earnings Growth: Management reiterated its focus on growing operating earnings in 2015. While Medicare rate pressures remain (-3 to -3.5%), the company is optimistic of better MA enrollment in 2015 as it does not expect the same level of market disruptions with more limited network reconfigurations...Medicaid is expected to remain a positive contributor. Additionally, UNH has $90B in medical costs and $20B in administrative costs from which to drive savings, which was stressed by management during the meetings...cost creep has backfilled previous administrative cost savings. Management is now "acutely focused" on applying more rigorous standards to general reinvestments in the organization.

â–      Medicare Star Ratings and Renewed Focus on Performance: While the management team noted that performance as a whole has been "good", there was clearly a sentiment that performance needs to improve. Hemsley noted that too many of UnitedHealthcare's recent issues have been "self-inflicted," especially Medicare Stars. As a result, UNH is in the process of narrowing its networks to steer patients to high performing providers in an effort to improve quality. Additionally, a greater focus will be placed on leveraging data to stratify members in order to quickly identify and place high acuity members in appropriate care management programs. As the largest player in the market, UNH has several metrics under its control and is expected to perform at high levels. According to management, it took UHC too long to figure out that STAR ratings place significant emphasis on serving both the healthcare and social needs of members. While corrective steps are encouraging the improvement in STAR rating won't be evident until 2017 at the earliest given the lag time in measuring criteria.

â–     Network Reconfigurations Continue: As a result of MA rate pressures, UNH significantly adjusted its networks during the 2014 annual enrollment period for which it received scrutiny. Management reiterated that network reconfigurations will continue, but will be guided by insights gained during 2014. Last year UNH narrowed its Medicare networks by 10-15% and management expects some continuation into 2015, although changes will be made more on a continuous basis vs. occurring all at once and therefore should be less disruptive. Overall, network configuration remains a significant component of managing trend and should not be underestimated as narrowing networks to higher performing facilities/providers can save on medical costs. MA rate pressures for 2015 were evident when management reiterated that the final rate came in below their expectation of flat. UNH sizes the impact in the range of -3% to -3.5%.  We would expect network reconfigurations to be an ongoing process, as management believes it is only in the 2nd or 3rd inning, but again, don't expect big disruption like 2014.

â–      Reform Update: While UNH's exchange participation in 2014 was limited, it is inclined to increase its involvement in 2015. UNH is currently in the process of evaluating markets, products, regulations, and first year pricing. While it continues to appear that the company is likely to increase its exchange exposure in 2015, it has until September to finalize its decisions.

â–     Medicaid: Expansion also appears to be tracking well, as management now expects Medicaid growth to exceed the high end of guidance (+350-450K lives). While the dust has yet to settle, expectations were to see 65% of expansion enrollment 1Q, followed by more moderate enrollment in the middle of the year and a reacceleration around year end. It is still early, but at this point UNH has not seen anything alarming in terms of utilization and feels comfortable about its ability to effectively manage new Medicaid members. Additionally, UNH is getting paid appropriately higher rates for Medicaid expansion members.

â–      Optum: Management's new goals are "8 by '16" (8% operating margins, 10 new large relationships, double digit top and bottom line growth, and doubling 2013 op earnings of $2.3B). With a backlog of $7.2B, Optum has an abundance of opportunities at its fingertips...Optum's role as a system integrator for HealthCare.gov was an important building block in establishing its reputation. Management also conveyed a new level of confidence that scrutiny around Optum's association with UNH has subsided, as payors and healthcare systems appear to have gained comfort that the appropriate firewalls are in place for Optum to maintain its independence from UNH.

 

Resources

On May 7, Gorman Health Group Executive Vice President and former regulator Steve Balcerzak joined Vice President of Provider Network Management Craig Lyon for a deep dive into CMS expectations. Attendees got their their take on what to expect and how to prepare. Access the webinar recording here >>

From ACO-type incentives to bundled payments and contract capitation, to full professional and global capitation — where the potential is promising, we can help design and implement these arrangements. Contact us for more information >>

 


POTUS Spikes the Football, but the ObamaCare War-Game Isn't Over

Last week as health insurance exchange open enrollment ended, President Obama spiked the football, announcing that 8 million people had signed up, and that the Obamacare debate is "over."  He put an exclamation point on it: that millions more had gained coverage through Medicaid expansion and new mandates on employers.  Now, any further discussion of repealing ObamaCare was about taking coverage away from those millions of Americans.

Republicans, sickened by a blinding case of ObamaCare Derangement Syndrome (ODS -- it's in DSM-4, check it out ;)), predictably wailed.  "The Debate Will Be Over When the American People Say It's Over," The Weekly Standard‘s Jeffery A. Anderson blogged the next morning.

POTUS is right.  This train has left the station.  ObamaCare, like Medicare Part D in 2006, is now a part of the firmament of the American health system, and can't be dismantled without a Republican in the White House.  And as far as the American public goes, they're done with this repeal nonsense too.  Last month, the Kaiser Family Foundation released its monthly polling and found approval of the law rising, especially among the uninsured. 53% of Americans are "tired of hearing about the debate over the ACA and want the country to focus more on other issues."  Can we get an amen?  Look, it ain't popular -- yet, remember it took the Medicare drug benefit 2 years before opinion turned -- but it's not going away.

But that doesn't mean the repeal fight ends.  Oh no.  Two things guarantee that: the tax on the wealthy that funds a big piece of ObamaCare, and the Citizens United and McCutcheon cases in the Supreme Court.  The New York Times‘ explains: Under the Affordable Care Act, the Medicare payroll tax increased by 0.9% in 2013, but only for couples earning $250,000+ and unmarried taxpayers earning $200,000+. That tax hits just 2% of taxpayers, but helps to explain the spread of ODS among Republicans.

Combine that with virtually unlimited funding for campaign-style ads and events under the Citizens United and McCutcheon decisions,  which enable a small number of families to donate more in one election cycle than most Americans will earn in their whole life, and we're looking at a virtually endless ObamaCare war of dead-ender fundraising, attack ads, and futile repeal attempts.

What's more, it seems increasingly likely that Republicans will regain control of the US Senate in the 2014 midterms, putting Congress entirely under GOP control.  I wouldn't be surprised to see articles of impeachment filed early in 2015 as ObamaCare Derangement Syndrome sweeps over Capitol Hill.  It will be an ugly conclusion to the Obama Administration, but it won't end in repeal, that much is certain. Republicans will just pretend like it could.

 

Resources

Exchange enrollment is a multi-pronged strategy with member outreach and connection embedded within. Find out more about how GHG can help you with your strategy >>