Minnesota Hospital Association

Policy & Advocacy

rules, regulations and comments

The Minnesota Hospital Association continually monitors state and federal rules and regulations to keep members informed and advocates on behalf of members regarding the impact of regulations on the state’s hospitals and health systems. MHA submits comment letters to share recommendations and feedback with the appropriate government organizations and health care stakeholders. Examples of rules and regulations that MHA addresses include those implementing federal or state health care reform efforts, changing payment methodologies, establishing community benefit or other standards for tax-exempt organizations, or modifying government oversight of health care activities.

September 24, 2012

MN Health Insurance Exchange Advisory Task Force's draft guiding principles

 Sept. 24, 2012

Submitted electronically

TO: Members of the Health Insurance Exchange advisory Task Force
RE:  Task Force's Draft Guiding Principles

On behalf of our members, which include 145 hospitals and 17 health systems throughout Minnesota, the Minnesota Hospital Association (MHA) appreciates the opportunity to provide the following comments regarding the Minnesota Heath Insurance Exchange Advisory Task Force's draft guiding principles.

MHA supports the creation of a Health Insurance Exchange (Exchange) in Minnesota. We prefer that Minnesota's Exchange be created by, governed by and operated by Minnesotans rather than the federal government. Also, MHA believes that the Exchange should be insulated from partisanship and, therefore, we prefer that Minnesota's Exchange be operated as a nonprofit organization or a public-private partnership instead of existing within a state agency.

With respect to the Task Force's draft principles, MHA supports the general direction and aspiration statements. However, we have concerns that the draft principles overemphasize the Exchange's role in reforming the health care delivery system and underemphasize its role in reforming the health insurance market for individuals and small businesses. Consequently, the draft principles create a scope that is too broad for the Exchange. Instead, MHA respectfully suggests that the Task Force reexamine the draft and take the hard step of focusing the principles on the functions and roles that the Exchange can and should play in Minnesota. Specifically, MHA encourages the Task Force to revise the draft to explicitly and clearly address the Exchange's role in facilitating the transaction between Qualified Health Plan offerors and purchasers.

Also, MHA is confused about the role and authority of the Task Force. In presentations and discussions, state employees in leadership positions with the Exchange emphasize that the Task Force is an advisory body. Yet, in the draft principles, the language used gives the impression that the Task Force has a role with much more authority. The draft states that the Task Force will "design an Exchange" and "develop the Exchange." MHA urges the Task Force and/or the Administration to be very clear about the role of the Task Force; its decision-making authority, if any; and the lines of accountability for Exchange policy, design and development.

MHA offers the following concrete suggestions for re-wording some of the provisions in the draft:

Universal Coverage: add "coverage" after "health care" and before "all Minnesotans."

High Quality, Affordable Health Care: revise the sentence to read as follows: "The Task Force's recommendations will support designing an Exchange that promotes the availability of high quality health care coverage at an affordable cost, encouraging innovative Qualified Health Plans that increase value.

Competition: revise the statement to read as follows: "The Task Force's advice will support developing the Exchange in a way that fosters vigorous and fair competition among Qualified Health Plans to increase value for Exchange users.

If Task Force members or others have questions or concerns about any of these comments, feel free to contact me anytime. Again, thank you for providing the opportunity for public comment.

Sincerely,

Matthew L. Anderson, J.D.
Vice President, Regulatory and Strategic Affairs
Minnesota Hospital Association