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Black Boxes and BeyondAgenda
Current Landscape
Approach, Implementation and Timelines
Medical Concierge
Navigant Report – North Carolina
Claims Recovery
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ASO and Risk Management
Plan Design…wellness, telemedicine
The Current LandscapeLack of Transparency
What if it became normative business practice for your payroll service provider to set salary and wage increases and after years of near double digit increases you request an audit and are told it’s their proprietary information and really off limits to you, the employer?
Sound absurd?
It is, but this is the normative landscape for many
self-insured employer group health plans in
the country.
TransparencyTransparent Negotiations, Networks and Fees
“The lack of price information
stems from the confidential
nature of negotiations between
providers and payors.
Providers compete with each
other trying to get the highest
payment from payors, and
payors compete with each other
trying to set the lowest payments
to providers. In hopes of getting
the best deal, both providers and
payors want their
negotiated rates to be kept
confidential. Information is kept
from the consumer that is
necessary to make the best
choices and drive an improved
market.” Will Fox, 2011
insight – Expert Thinking From Milliman
Transparency
Solutions for
the Future
Recovery from
the Past
Performance Audit State Health Plan Risk Assessment September 2011
Plan Participant Totals 662,000 lives and equates to $2.8 Billion spend
“Although the Plan pays BCBSNC to access its provider network and
to benefit from its contracted discount rates with medical providers, all
contracts are between BCBSNC and its providers and are considered
proprietary information….Consequently, the plan is at risk for overpaying
claims because it must rely solely on BCBXNC auditors and information
from BCBSNC computer system to identify discount errors.”
Beth Woods, CPA, State Auditor
Navigant ConsultingPerformance/Efficiency Audit
Because of the test nature and other inherent
limitations of an audit, together with limitations of any
system of internal and management controls, this
audit would not necessarily disclose all performance
weaknesses or lack of compliance.
Minimal Fraud
Recovery Efforts
Standard
Business
Practice Flaws
Methodology =
Transparency
Navigant ConsultingPerformance/Efficiency Audit
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“Specifically, the Plan does
not follow up on potential
overpayments estimated by
Plan auditors, does not
provide adequate oversight
for its recovery audit
function, has not taken
corrective action to
eliminate or reduce
potential errors, and cannot
independently verify that the
Plan receives the proper
discount rate on medical
claims.”
t
ASO
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ASO
“The State Health Plan’s
contract with Medco lacks
provisions that would
provide the SHP information
that is important to its
oversight of contractor
performance. The contract
does not require Medco to
provide information about
the unit cost of
pharmaceuticals to the
State Health Plan. In
addition, the current
contract with Medco does
not allow the SHP to audit
the MAC list to determine
the competitiveness of
Medco’s pricing.”
PBM
32“The State Health Plan
does not have policies
and procedures in place
to mitigate certain risks
that could result in
overpayments on member
medical claims.”
Your own sub headlineIt’s Your Money
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3Therefore – any and all funds should have no “lock boxes” or “proprietary contracts” reducing the
efficiency of your health care plan!!!
Transparency is the KEY!
Two of every Three “health insurance” plans in the U.S. are “self insured plans”, meaning, there is NO
policy. The employer is the insurer.
Welfare Benefit Plans
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The TPA is merely a paperwork processor, an intermediary. ALL money paid for health claims is “Plan
money” supplied through the employers Welfare Benefit Plan.
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Third Party Administrator
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•Risk Management – Structure Determines Function
Pure Risk vs. Speculative
Plan Design for optimal outcomes
CDHP
Wellness
Concierge
Telemedicine
•Risk Management
Infrastructure for optimal outcomes
Proprietary Networks
Cost Plus
Real Time
Can one cut costs and deliver better benefits?
“You cut costs by
eliminating claims
or reducing the cost
per claim.” Ron Dobervich
What Do Optimal Medical Outcomes at Lowest
Net Cost Really Mean?
In 2009, Our proprietary
net-work system’s clients
averaged a composite cost for
benefit plans 28.6% below the
Kaiser Foundation’s published
national average.
Cost Plus is Quantifiable: The numbers
tell the story….
Data driven diagram – Line diagram
$1,880,795 $1,130,134 41.33% $299,602 77.83%
377% Difference DO YOU THINK THIS WILL
AFFECT TREND?
Risk Management Done Right
Robust Case
Management if
Needed.
Subject to over
230 Proprietary
Networks.
Claim incurred.
Hospital claims
are subject
to COST
Plus audits.
Hospitals are
paid more on
average - all
while you save
money.
Your data
accessible in
real time.
Virtual OnSite: This is our Network
system’s name for its administrative
services product in which administrative
operations occur at the client’s worksite,
with client access to individual records
and reports via secure Internet access.
You will have access to information
regarding your health plan as if you
were administering the benefits on-site
at your facilities.
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Imagine owning your own data!Data – unencumbered by ”proprietary” contracts....
Cost Plus
Proprietary Networks
Real Time
Data
Plan Design
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A qualified high deductible plan
coupled with an HSA or HRA can
equate to significant savings without
sacrificing benefits.
CDHP
A standard based or participatory
plan can incent healthy behavior.
Wellness
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A concierge service that shops cost
effective procedures and
telemedicine for consumer
convenience.
Tools to further efficiency
With regard to first year cost savings, all
studies showed a favorable effect on cost the
first year of a CDH plan. CDH plan trends
ranged from -4 percent to -15 percent.
Coupled with a control population on
traditional plans that experienced trends of +8
percent to +9 percent, the total savings
generated could be as much as 12 percent to
20 percent in the first year. All studies used
some variation of normalization or control
groups to account for selection bias.
American Academy of Actuaries
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TransparencyTransparent Negotiations, Networks and Fees
“In no other area of our economy
do consumers receive services
where they do not know the cost
in advance and are
not able to make comparisons to
alternative suppliers. As a result,
healthcare provider costs have
remained immune
from the economic forces that
could control them. This
immunity has contributed to
greatly increasing provider costs,
a major component in todays
rising healthcare costs.”
Will Fox, 2011
insight – Expert Thinking From Milliman
Transparency
Solutions for
the Future
Recovery from
the Past
Medical Concierge
395% Difference
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A single procedure can have price variation of 500% or more and facility charges ranging 1,000%.
So how do you know if your getting the best price? YOU DON’T – “Blind by Design”
$291
$2,089717%MAX RISK
Providers often pay large sums back to
intermediaries. These payments in the provider
world are called “overpayments” or
“recoupments”.
Intermediaries have several, complex, often
obscure, methods of receiving theses monies.
Our discussions with traditional audit firms
demonstrate they are often not familiar with the
provider claims nor ERISA regulations pertaining
to those claims and hence, are not aware of all
the sources of your refunded money.
Recovery from the Past
Who should
audit?
Recoupments
Overpayments
Recovery from the past…Who should audit your plan?
“The lack of follow-up will prevent the Plan from identifying and correcting the conditions that allowed the overpayments to occur. Additionally, the Plan will fail to recapture a potentially significant amount of overpayments.”
Beth Wood, CPA, State Auditor
In fact, a 2010 performance review by Navigant Consulting, Inc.
indicates that the Plan does not receive value for money on its fraud
recovery audit efforts. Navigant noted that fraud recovery efforts by
the Plan’s vendor, Blue Cross Blue Shield of North Carolina (BCBSNC),
do not meet industry standards.
“BCBSNC’s level of fraud recoveries for the SHP [State Health Plan] is
well below the industry average. For every $1 the SHP spent on fraud
and abuse detection, the SHP received only 10 cents in actual fraud recoveries.
Overall, the BCBSNC recovery dollars are equal to a little more than 1 percent of the SHP’s total medical expenses, which is significantly below the industry average of 3 to 5 percent.”
Federal Court Ruling
Recovery from the past….
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Federal Court Ruled Against BCBSRI's
Overpayment Practice on October 27,
2010 - Relied Upon U.S. Supreme Court
ERISA Rulings
The Court Ruled that BCBSRI’s Post-
Payment Overpayment Recoupment is a
Plan Fiduciary Conduct Governed by
Federal Law ERISA Instead of Provider
PPO Contract.
Subsequent Federal Court Rulings Give
Self-Insured Health Plans solid foundation
to proceed.
Self Insured Welfare Benefit
Plans have a fiduciary
obligation to pursue these
funds.
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Proprietary Networks
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Cost Plus