March 12, 2019
Senator Michelle Benson
95 University Ave. W.
Minnesota Senate Building, Room 3109
St. Paul, MN 55155
Representative Tina Liebling
100 Rev. Dr. Martin Luther King Jr. Blvd.
477 State Office Building
St. Paul, MN 55155
Via email: email@example.com and firstname.lastname@example.org
Dear Sen. Benson and Rep. Liebling:
The 141 hospital and health system members of the Minnesota Hospital
Association (MHA) provide a range of services across the health care continuum
for patients and communities throughout Minnesota. Because our members have
strong interests in the state’s public and private health coverage markets, MHA
is closely following discussions at the Legislature regarding proposed changes
to the individual market. Rep. Liebling’s House File 3 and its expected DE1-2
amendment is one such proposal, and we are reviewing it closely.
Given that the proposed changes would not go into effect for several
years, MHA respectfully requests that you and your colleagues consider creating
a forum and process for policymakers and stakeholders to have thoughtful,
deliberate and well-informed discussions about reforms of this scope and
As reflected in the DE1-2 amendment, MHA has many questions about the
various pieces of the proposal. For example, the proposal would establish a new
methodology for calculating providers’ reimbursement rates from new
state-sponsored health plans. In merely four lines of the bill, one can
appreciate the amount of complexity and high stakes that are in play.
- The proposal would establish provider payment
rates “targeted to the current rates” in state public programs (Line 13.26).
- What degree of latitude does “targeted to” give
state agencies when setting provider rates?
- Will “current rates” be defined as the payment
rates in place upon the date of enactment, the effective date, the date an
enrollee receives a service, the date a provider submits a claim or some other
point in time?
- Because a large portion of state public programs
are administered through Prepaid Medical Assistance Plans (PMAPs), how will the
state determine “current rates”?
- Will it use only fee-for-service rates or some
form of blended average of fee-for-service and all PMAPs’ provider payment
- These four lines also state that provider
payment rates will be enhanced by “the aggregate difference between those rates
and Medicare rates” (Line 13.27)
- What is the methodology for calculating the
- Is that calculation made on a
service-by-service, code-by-code basis?
- Is it risk adjusted?
- Does this reference to “Medicare rates” mean
Medicare fee-for-service rates?
- Will critical access hospitals’ payments be
based on their costs, as is the case with their Medicare payment rates, or will
they be subject to the same rates as larger hospitals?
- Will the Medicare rates used for this
calculation include the portion of Medicare payment rates reflecting medical
education costs or disproportionate share hospital payments?
Again, these are examples of the number and range of extremely
significant questions MHA has in only one small section of the bill. We raise
them not as criticism of the bill drafting, but rather to highlight the
importance of taking the time necessary to understand, analyze and evaluate the
changes called for in the bill as well as the possibility of other options
before making final decisions on what is in the best interest of our residents.
MHA looks forward to working with you, your fellow committee members,
your colleagues and the Senate and House staff experts, as well as leaders in
the governor’s administration and our fellow stakeholders to explore and
develop the best approaches to ensure affordable, comprehensive and meaningful
health coverage for every Minnesotan.
Lawrence J. Massa, M.S., FACHE
President & CEO
C: Rep. Rena Moran; Sen. Jim Abeler; and Commissioner Tony Lourey