CAHC Calls for New Transparency Measures, Subsidy Portability in ASPE Comment Letter

WASHINGTON, DC (January 25, 2018): The Council for Affordable Health Coverage (CAHC)  responded today to a request for information (RFI) from the U.S. Department of Health & Human Services' Office of the Assistant Secretary for Planning and Evaluation (ASPE).

In the RFI, ASPE seeks stakeholder comments on solutions to "promote competition in healthcare markets and limit excessive consolidation throughout the healthcare system." CAHC answered by encouraging reforms to:

  • Improve price and quality transparency to empower consumers in plan and provider choices;
  • Expand and improve data to power private consumer transparency tools;
  • Allow consumers to vote with their feet by making premium subsidies portable;
  • Allow private eCommerce companies to compete to enroll consumers in health plans;
  • Expand plan choices, including account-based options;
  • Reform outdated laws that prevent value, care coordination and shared incentives to improve care;
  • Ban anti-competitive contract provisions that harm consumers and drive up costs, such as “anti-tiering” or “anti-steering” clauses; and
  • Reform Medicare policies that encourage care in higher cost settings.

"We appreciate ASPE's desire to address anti-competitive government policies and stem the tide of market concentration. In our response to the agency's request for information, we have laid out a roadmap of actionable, market-based policy solutions to increase competition, improve access, foster and expand informed consumer choice, promote value, and empower patients," said CAHC President Joel White. "With health costs consuming 35 percent of the typical family's income, the stakes are too high for inaction. We stand ready to work with ASPE and other policymakers to implement the reforms necessary to change this broken status quo and improve pathways to quality, affordable care." 

In its comment letter, CAHC noted recent statistics on healthcare competition and spending, including findings which report that, in 2016, 90 percent of metropolitan areas had highly concentrated hospital markets, 65 percent had highly concentrated specialist physician markets, 39 percent had highly concentrated primary care physician markets, and 57 percent had highly concentrated insurance markets.

CAHC also pointed to research from Dartmouth Health Atlas estimating that 30 percent of health spending—more than $1 trillion in 2018—is "waste." CAHC added that "A reduction of this magnitude would raise worker incomes while substantially eliminating federal budget imbalances. Strengthening the business case for productivity may be the single most important object of health market reform." 

Specific policy changes proposed in CAHC's comments include: directing healthcare facilities to post the average cash price for the most common tests and procedures, issuing administrative rules to prohibit information blocking and to promote interoperability, establishing clear exceptions to pricing models (e.g., Medicaid best price) that inhibit value-based arrangements, and paring down the role of in the federal marketplace, allowing private exchanges to lead the way in facilitating enrollment. 

Read CAHC's full RFI response here


About CAHC:
The Council for Affordable Health Coverage (CAHC) is a broad-based alliance with a primary focus: bringing down the cost of health care for all Americans. CAHC promotes policies that lower health costs through increased competition, informed consumers and more choices to help promote access to affordable coverage. Learn more at