SIM comments on financial incentives, consumer surveys

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SIM has started floating their proposals to implement health care reform in CT and #2in particular is troubling for consumers. One proposal offered as a financing option by SIM staff would replace advanced payments for new, effective services such as care coordination and medication management with shared savings payments. This could create unfortunate incentives to parse patient panels and deliver those services only to patients who can produce savings. The incentives to recoup investments not guaranteed by advanced payments, are similar to downside risk. SIM has repeatedly affirmed the likely value of these new services and stated their intention to encourage them. Netting their cost out of or completely replacing them with shared savings payments would undermine that commitment. Interestingly, other new treatments — drugs and therapies — that are expected to add value and keep people healthy, are not disincentivized. These new services are no less valuable because they are not traditional care.

Policy papers #1and #2are doubtless only the beginning of a flood of policy proposals. Stay tuned for more comments from consumer advocates.

Note: Independent consumer advocates also submitted comments to SIM opposing any state of mind test to enforcement of under service standards.