While consumers may not understand the ins and outs of HIPAA, they have a general sense that they have privacy rights when it comes to their healthcare information. Sapphire Digital strongly suggests that the Federal Trade Commission "FTC" develop a privacy and security framework for the health applications accessing this data that is at least as restrictive as the HIPAA privacy and security standards before permitting these third parties to have access to this data.
Health Plans, including our clients, have taken significant steps towards increasing the availability of meaningful price information, including on-line transparency tools that are coupled with telephonic support. These tools integrate data and personalized service to support consumers. The public disclosure of the dataset as proposed will not eliminate the need for health insurance providers to provide timely, accurate and personalized cost-sharing information.
If a consumer looks at an individual price, he or she may believe they have an exact price for the procedure, and he or she may be very surprised when they receive the ultimate bill. Health Plan tools have been created to help avoid this confusion. We ask that the administration eliminate the requirement that Health Plans disclose negotiated rates and out-of-network allowed amounts in machine readable format on a public website, and instead allow the Health Plans to keep innovating and improving the consumer-focused tools already in the market, such as Sapphire Digital's CareSelect Platform.
Sapphire Digital , as one of the leading vendors in the healthcare transparency industry, has significant concerns that the implementation timeline of one year from rule finalization is not feasible.
The Proposed Rule is operationally complex and requires new technology and data sets to be built and tested by Health Plans. Sapphire Digital worries that the timing requirement may undermine the effectiveness of the Departments' effort under the Proposed Rule. We strongly recommend that the Proposed Rule not go into effect until at least 2 years from finalization for the following reasons:. Moreover, Health Plans are not able to contract with just any vendor to satisfy the requirements of the Proposed Rule.
The Health Plan and PBM systems have different technical infrastructures that cannot readily interface with the current systems in place for medical services. Therefore, Sapphire Digital requests that the requirement that drug pricing information be included with an individual's estimated cost sharing liability be removed from the Proposed Regulation at this time.
We request that CMS work with Health Plans, PBMs and vendors such as Sapphire Digital to come up with a strategic and thoughtful approach for incorporating applicable pharmacy data into the Health Plan's on-line tool or through other means, such as by allowing the Health Plan's on-line tool to link to a separate PBM system. For certain procedures, NCCT utilizes a cost range for the total cost associated with the episode of care in order to simplify how the cost information is provided to the consumer.
If the Proposed Rule goes into effect, Health Plans, such as the Blue plans using the NCCT, will be required to make significant changes to how they approach cost transparency through their existing consumer tools. This will require the investment of a significant amount of time, effort and resources by the Health Plans in order to comply with the Proposed Rule and is unlikely to be operational within one year of rule finalization.
Sapphire Digital appreciates this opportunity to comment on these important provisions in the Proposed Rule. Should you have any questions or wish to discuss our comments further, please contact me at or [email protected].
Additional information is also provided on the final page of this letter. For the Departments' reference, Sapphire Digital operates the SmartShopper Program, which is the shared savings program utilized by the State of Kentucky that is described in the Proposed Rule and in footnote Sapphire Digital believes the MLR provision should be implemented as soon as the rule is finalized and should be applicable for the MLR Reporting year.
The CareSelect Transparency platform's fully integrated solution makes it simple for consumers to find care, understand health care costs and choose preferred options. The SmartShopper incentive and redirection program allows consumers to shop for routine health care procedures on-line, or over the phone with a Personal Assistant.
When consumers select a high-quality, lower-cost option, they receive a share of the savings in the form of a cash incentive or other reward. Health Plans save money, consumers save on their out-of-pocket costs and get cash back.
MEG provides access to composite quality scores to help consumers find the best surgeon and hospital combination for their surgery, at a predictable cost. Our clinically trained Surgical Concierges guide consumers through every step of the care journey, assisting with physician and facility comparison and selection, appointment scheduling, care coordination, incentive information, and pre and post procedure support.
Our advanced analytics use claims data to allow Health Plans to customize surgical networks that best support their specific network and contracting strategies as well as support a member along their care journey through early notification and engagement. Remember Me. Targeted News Service. Become an INNsider. Quality and Safety. Billing and Collections.
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