CHA News

Letters to OHCA Board Highlight New Data, Caution Against Overly Broad Review Process

What’s happening: Last week, CHA submitted two letters to the Office of Health Care Affordability (OHCA) — one responding to the May OHCA board meeting, and another addressing the office’s proposed changes to the cost and market impact review (CMIR) regulations.  

What else to know: The board met June 26 to approve the alternative payment model (APM) standards and discuss the proposed CMIR regulations, the draft workforce stability standards, and the draft primary care investment benchmark.   

CHA’s letter in follow up to the OHCA board’s May meeting shared new health care spending projections from the Centers for Medicare & Medicaid Services (CMS) that the office should use to inform its work. CMS’ projections showed how aging and utilization will increase health care spending going forward, and that price growth over the next several years will serve to correct a huge imbalance between health care providers’ revenues and expenditures that grew during and following the COVID-19 pandemic. CHA also encouraged OHCA to take lessons learned from a recently awarded state contract for state employee and retiree health benefits that includes affordability goals, as well as examine how OHCA’s APM adoption goals fit alongside its other activities and monitor for unintended consequences.  

In addition to addressing the overly broad notice requirements in OHCA’s proposed CMIR regulations, CHA’s comments highlight the office’s narrow focus on negative impacts as part of its review process; as currently written, the office would not consider in its review any potential gains that may result from a transaction. CHA encourages the office to take a more holistic approach to ensure prospective benefits — such as preventing the closure of a financially distressed entity, broadening access, integrating clinical functions across disparate providers, achieving economies of scale that result in real savings, and fostering collaboration in training new generations of health care providers — are equally considered in transaction reviews.