HFMA Comments on Request for Information Regarding Medical Payment Products

HFMA submitted comments to CMS on Request for Information Regarding Medical Payment Products. Hospitals are committed to fostering the health and well-being of their communities by delivering quality healthcare services. Their mission hinges on the accessibility of these services to patients, and as such, hospitals strive to eliminate any obstacles to care, especially financial ones. This commitment underpins their unwavering support for ensuring that every individual is enrolled in a comprehensive coverage plan. Moreover, when such coverage falls short, hospitals step in and contribute significantly by providing tens of billions in uncompensated care annually. In fact, in 2020, the most recent data available, hospitals extended over $42 billion in uncompensated care, according The AHA’s 2020 Uncompensated Care Fact Sheet. Hospitals embrace and bear the profound responsibility of caring for anyone who seeks their assistance, irrespective of their ability to pay. In essence, they stand as the sole pillar of the healthcare system burdened with this remarkable duty.  Simultaneously, ensuring the provision of top-notch healthcare necessitates the allocation of resources, much like any other commodity or service. These resources encompass the remuneration for the dedicated healthcare professionals, including nurses, doctors, technicians, and support staff, who tirelessly tend to patients. They also encompass the maintenance of physical infrastructure, procurement of medical equipment, pharmaceuticals, implementation of cutting-edge technology systems, and the acquisition of various essential supplies vital for the delivery of healthcare.

In the comment Letter, HFMA highly recommends the agency take steps in addressing the underlying factors that prompt patients to turn to medical payment products, primarily by reducing the prevalence of unmanageable healthcare expenses. This can be accomplished by ensuring that all individuals have access to comprehensive healthcare coverage with affordable cost-sharing. Such an approach not only diminishes the necessity for medical payment products, thus mitigating the risks associated with potentially exploitative options, but also yields numerous advantages for patients, employers, communities, and healthcare providers. The following are five concrete proposals aimed at preventing patients from encountering unaffordable healthcare costs:

1. Sustain efforts to ensure universal enrollment in comprehensive healthcare coverage for all individuals.
2. Consider alleviating providers from the collection of cost-sharing by encouraging health plans, the entities determining enrollees’ financial obligations, to directly collect the required cost-sharing amounts. This would significantly reduce patient bills from providers and other care givers.
3. Restrict the availability of high-deductible health plans to individuals who can demonstrate the capacity to afford the associated cost-sharing.
4. Prohibit the sale of health sharing ministry products and short-term, limited-duration plans that extend coverage beyond 90 days.
5. Lower the maximum allowable out-of-pocket cost limits.