New direct primary care rules are a tough pill for HSAs
For many Americans, direct primary care has taken control of medical costs, which has cut through many frustrating options and has created a peach of mind when it comes to both health and its costs. Read this blog post to learn more
As an employee benefits attorney and compliance consultant, last summer’s executive order on “improving price and quality transparency in American healthcare to put patients first” piqued my interest. In particular, I honed on in section 6(b), aimed at treating expenses related to direct primary care arrangements as eligible medical expenses.
As someone dealing with a complicated medical history, digging into the order and digesting the resultant proposed IRS rule was more than my job – it was and is part of my life.
Several years ago, I decided to give direct primary care a try. For about $100 a month, I gained direct access to and the undivided attention of a physician who knows me and my unique medical needs. I pay a flat, upfront fee and my doctor coordinates and manages my treatment, which isn’t always smooth sailing for someone dealing with a complex connective tissue disorder. My primary care physician serves as the coach and quarterback of my medical care, directing tests, meds, and visits to various specialists like rheumatologists or neurologists. If I have a common cold or infection, she’s readily available to prescribe treatment and set my mind at ease.
Since arriving on the scene in the 2000s, direct primary care has grown in popularity and availability. In the age of skyrocketing monthly premiums and a multitude of confusing options, more Americans are flocking to direct primary care to supplement their existing coverage. Some employers are even looking at it to drive down costs.
Now, direct primary care only covers, well, primary care, so I’ve paired it with a high-deductible healthcare plan and a health savings account to pay for my many additional medical expenses. I’m not alone: more than 21 million Americans are following the same path.
However, rather than making direct primary care more accessible, the proposed regulations actually make it virtually impossible for all of us with HSAs. Remember, by law, to qualify for an HSA, individuals must be covered by a high deductible health insurance plan. The rationale for this is consumers with more on the line are more responsible in controlling their health care costs and thus rewarded with the tax-advantaged benefits of an HSA.
Here’s the problem: the proposed regulations define direct primary care as a form of insurance – one that is not a high-deductible health plan and would therefore disqualify me from having access to an HSA.
Regulators point out that direct primary care arrangements provide various services like checkups, vaccinations, urgent care, lab tests, and diagnostics before the high deductible has been satisfied. According to the preamble to the proposed regulations, “an individual generally is not eligible to contribute to an HSA if that individual is covered by a direct primary care arrangement.”
Keep in mind, 32 states consider direct primary care a medical service rather than a health plan and exempt it from insurance regulation. Even the Department of Health and Human Services shares that view, noting in a March 12, 2012, final exchange rule that “direct primary care medical homes are not insurance.” In addition, the proposed rule itself includes some contradictory language and implications when it comes to defining direct primary care relating to other factors.
By its very nature, direct primary care is a contract between patient and physician without billing a third party. In cutting out the insurance companies, it seems obvious that direct primary care is not a competing insurance plan, but instead, a valuable service that can accompany existing coverage.
Furthermore, there is no clear justification for painting direct primary care as disqualifying medical insurance for those with HSAs. The IRS has more than enough flexibility and discretion to determine that direct primary care does not count as insurance. Regulators could do so while still treating direct primary care as a tax-deductible medical expense, which seems to be the intention of the proposed rule in the first place.
For millions of Americans, direct primary care has been a godsend in taking control of medical care, cutting through frustrating options, and gaining peace of mind when it comes to both health and healthcare costs. In short, direct primary care is everything primary care should be and was supposed to be. It’s an option that individuals should be permitted to access to complement (not compete with) high deductible health insurance plans and HSAs.
Although the comment period for the proposed regulations is now over, I am hopeful with a few tweaks and small changes they can better align with the stated purpose of the executive order, empowering patients to choose the healthcare that is best for them. If not, the new rules would likely be a hard pill to swallow for the entire direct primary care community.
SOURCE: Berman, J. (26 August 2020) "New direct primary care rules are a tough pill for HSAs" (Web Blog Post). Retrieved from https://www.employeebenefitadviser.com/opinion/new-direct-primary-care-rules-are-a-tough-pill-for-hsas
No primary care doc, no problem: How millennials are changing healthcare
Do you have a primary care physician? Forty-five percent of 18- to 29-year-olds reported that they do not have a primary care physician. Read this blog post from Employee Benefit News to learn more.
Millennials, and Generation Z behind them, are changing the way they access healthcare. In fact, 45% of 18- to 29-year-olds say they don’t have a primary care physician. Instead, they’re opting for on-demand healthcare.
Traditionally, individuals and families see primary care physicians several times a year and build relationships with their doctors over time. Visiting the same primary care physician when an illness strikes, or for an annual wellness checkup, can help the doctor notice changes in a patient’s health and catch issues before they become more serious (and costly).
But for millennials, having a primary care physician isn’t necessarily a priority.
That’s in part because they seem to prefer on-demand healthcare options, such as urgent care, drug store clinics and telemedicine services, which are easily accessible and typically include shorter wait times. The number of urgent care centers reflects the trend — they’re projected to grow by 5.8% in 2018, according to the Urgent Care Association.
Then there is employers’ shift away from health maintenance organizations, which often required that each employee choose a primary care doctor at the start of the plan. HMOs also require a referral from the primary care physician to see specialists. Recent research shows that most often, employers offer preferred provider organizations (84%), while 40% offer consumer-directed health plans and 35% offer HMOs.
Finally, physician shortages are leading to longer wait times for appointments. The U.S. population continues to grow and age, which may lead to a shortage of 120,000 primary and specialty doctors by 2030, according to the Association of American Medical Colleges.
For employers, it’s important to understand the reasons behind the shift to on-demand healthcare and educate employees to ensure they can get appropriate medical attention when they need it.
One crucial part of this education is helping employees understand when they should visit urgent care versus the emergency room, and reminding them that telemedicine is available. More than 95% of large employers and just over one-third of small- and mid-size employers offer telemedicine benefits. But adoption rates among employees remain low — only 20% of large employers report utilization rates above 8%, according to the National Business Group on Health.
Ensure your employees know that the service is available throughout the year and help them understand the cost if any is associated with the service. You may consider offering $0 copays for telemedicine visits to encourage employee use.
Encourage employees to get a wellness visit each year to help uncover health issues and take steps to prevent others. One way to do this without forcing employees to wait for an appointment or commit to a doctor is to bring the service in-house. Increasingly, large employers are adding this service to help employees stay healthy. In fact, one-third of employers with more than 5,000 employees and 16% of employers with 500-4,999 employees now have onsite clinics. Another 8% of midsize employers plan to add clinics in 2019.
Providing health assessments as part of a health and wellness program is another way to get employees, especially money conscious millennials, in front of a doctor. Younger workers are likely to embrace incentives or premium discounts that are tied to a physician visit.
Direct primary care is yet another employer option to provide easy-to-access primary care. With direct primary care, employers partner with primary care physicians to offer a designated doctor for their employees. The benefit for employees is more face time with a doctor and the opportunity to get personalized care.
Importantly, employees who have known chronic issues should see a primary care doctor regularly to help monitor and manage their condition.
The trend toward seeking on-demand healthcare at alternative sites isn’t likely to reverse direction any time soon. Instead, it’s up to employers to understand why it’s happening and educate employees of all ages on their options for care.
SOURCE: Milne, J. (7 January 2019) "No primary care doc, no problem: How millennials are changing healthcare" (Web Blog Post). Retrieved from https://www.benefitnews.com/opinion/no-primary-care-doc-no-problem-how-millennials-are-changing-healthcare?brief=00000152-14a5-d1cc-a5fa-7cff48fe0001
Are You And Your Primary Care Doc Ready To Talk About Your DNA?
Knowing your genes could save your life, especially if a genetic mutation is hereditary. See why incorporating DNA testing is a crucial part of your primary care.
If you have a genetic mutation that increases your risk for a treatable medical condition, would you want to know? For many people the answer is yes. But such information is not commonly part of routine primary care.
For patients at Geisinger Health System, that could soon change. Starting in the next month or so, the Pennsylvania-based system will offer DNA sequencing to 1,000 patients, with the goal to eventually extend the offer to all 3 million Geisinger patients.
The test will look for mutations in at least 77 genes that are associated with dozens of medical conditions ranging from heart disease to cancer, as well as variability in how people respond to pharmaceuticals based on heredity.
“We’re giving more precision to the very important decisions that people need to make,” said Dr. David Feinberg, Geisinger’s president and CEO. In the same way that primary care providers currently suggest checking someone’s cholesterol, “we would have that discussion with patients,” he said. “‘It looks like we haven’t done your genome. Why don’t we do that?’”
Some physicians and health policy analysts question whether such genetic information is necessary to provide good primary care — or feasible for many primary care physicians.
The new clinical program builds on a research biobank and genome-sequencing initiative called MyCode that Geisinger started in 2007 to collect and analyze its patients’ DNA. That effort has enrolled more than 200,000 people.
Like MyCode, the new clinical program is based on whole “exome” sequencing, analyzing the roughly 1 percent of the genome that provides instructions for making proteins, where most known disease-causing mutations occur.
Using this analysis, clinicians might be able to tell Geisinger patients that they have a genetic variant associated with Lynch syndrome, for example, which leads to increased risk of colon and other cancers, or familial hypercholesterolemia, which can result in high cholesterol levels and heart disease at a young age. Some people might learn they have increased susceptibility to malignant hyperthermia, a hereditary mutation that can be fatal since it causes a severe reaction to certain medications used during anesthesia.
Samples of a patient’s blood or spit are used to provide a DNA sample. After analysis, the results are sent to the patient’s primary care doctor.
Before speaking with the patient, the doctor takes a 30-minute online continuing education tutorial to review details about genetic testing and the disorder. Then the patient is informed and invited to meet with the primary care provider, along with a genetic counselor if desired. At that point, doctor and patient can discuss treatment and prevention options, including lifestyle changes like diet and exercise that can reduce the risk of disease.
About 3.5 percent of the people who’ve been tested through Geisinger’s research program had a genetic variant that could result in a medical problem for which clinicians can recommend steps to influence their health, Feinberg said. Only actionable mutations are communicated to patients. Geisinger won’t inform them if they have a variant of the APOE gene that increases their risk for Alzheimer’s disease, for example, because there’s no clinical treatment. (Geisinger is working toward developing a policy for how to handle these results if patients ask for them.)
Wendy Wilson, a Geisinger spokeswoman, said that what they’re doing is very different from direct-to-consumer services like 23andMe, which tests customers’ saliva to determine their genetic risk for several diseases and traits and makes the results available in an online report.
“Geisinger is prescribing DNA sequencing to patients and putting DNA results in electronic health records and actually creating an action plan to prevent that predisposition from occurring. We are preventing disease from happening,” she said.
Geisinger will absorb the estimated $300 to $500 cost of the sequencing test. Insurance companies typically don’t cover DNA sequencing and limit coverage for adult genetic tests for specific mutations, such as those related to the breast cancer susceptibility genes BRCA1 or BRCA2, unless the patient has a family history of the condition or other indications they’re at high risk.
“Most of the medical spending in America is done after people have gotten sick,” said Feinberg. “We think this will decrease spending on a lot of care.”
Some clinicians aren’t so sure. Dr. H. Gilbert Welch is a professor at the Dartmouth Institute for Health Policy and Clinical Practice who has authored books about overdiagnosis and overscreening, including “Less Medicine, More Health.”
He credited Geisinger with carefully targeting the genes in which it looks for actionable mutations instead of taking an all-encompassing approach. He acknowledged that for some conditions, like Lynch syndrome, people with genetic mutations would benefit from being followed closely. But he questioned the value of DNA sequencing to identify other conditions, such as some related to heart disease.
“What are we really going to do differently for those patients?” he asked. “We should all be concerned about heart disease. We should all exercise, we should eat real food.”
Welch said he was also concerned about the cascading effect of expensive and potentially harmful medical treatment when a genetic risk is identified.
“Doctors will feel the pressure to do something: start a medication, order a test, make a referral. You have to be careful. Bad things happen,” he said.
Other clinicians question primary care physicians’ comfort with and time for incorporating DNA sequencing into their practices.
A survey of nearly 500 primary care providers in the New York City area published in Health Affairs this month found that only a third of them had ordered a genetic test, given patients a genetic test result or referred one for genetic counseling in the past year.
Only a quarter of survey respondents said they felt prepared to work with patients who had genetic testing for common diseases or were at high risk for genetic conditions. Just 14 percent reported they were confident they could interpret genetic test results.
“Even though they had training, they felt unprepared to incorporate genomics into their practice,” said Dr. Carol Horowitz, a professor at the Icahn School of Medicine at Mount Sinai in New York, who co-authored the study.
Speaking as a busy primary care practitioner, she questioned the feasibility of adding genomic medicine to regular visits.
“Geisinger is a very well-resourced health system and they’ve made a decision to incorporate that into their practices,” she said. In Harlem, where Horowitz works as an internist, it could be a daunting challenge. “Our plates are already overflowing, and now you’re going to dump a lot more on our plate.”
SOURCE:
Andrews, M (12 June 2018). "Are You And Your Primary Care Doc Ready To Talk About Your DNA?" [Web Blog Post]. Retrieved from https://khn.org/news/are-you-and-your-primary-care-doc-ready-to-talk-about-your-dna/
Want to know what 2025 will look like?
BY KATHRYN MAYER
- Many needs, many models. This scenario is a natural extension of health care as many Americans know it. The scenario forecasts a shortage of primary care physicians, increased emphasis on disease prevention, growth in electronic medical recordkeeping, a shift from employee-based insurance to health insurance exchanges, and growing disparities in access to and quality of primary care based on income and where people live.
- Lost decade, lost health. This scenario forecasts a shortage of primary care physicians, declining income for practicing physicians and more uninsured patients, some of whom resort to black market care and unreliable online advice. Patients with good insurance have access to great care enhanced by advanced technology
- Primary care that works for all. This scenario assumes nearly universal health care coverage, with 85 percent of patients using integrated systems staffed by collaborative teams of health care providers, including physician assistants, nurse practitioners and health coaches who work closely with patients. Seeking to provide better care at lower cost while improving the health of the population they serve, primary care teams join with community partners to address factors that affect a community’s health, including employment, educational attainment, housing, transportation, and access to fruits and vegetables.
- Consumer is boss. Under this scenario, four of 10 patients opt for consumer-directed health plans, which include catastrophic insurance with high deductibles. For the most part, savvy consumers use advanced technologies, including noninvasive bio-monitors, as well as wellness and disease management apps, to stay healthy. Large vendors offer free avatar-based health coaching to consumers who purchase other integrated health products and services. Consumers shop for the best doctor and buy on the basis of high quality and low price.
