August 29, 2005
Deborah Drinkwater, Director of Health Care Delivery Systems
Premera Blue Cross
7001 - 220th SW
Mountlake Terrace, WA 98043
Dear Deborah,
As you are aware, the members of the Washington State Chiropractic
Association (WSCA) are extremely disappointed with the announcement
of a decreased fee schedule for services provided by chiropractic
physicians in Washington State. As our doctors’ business costs
increase and fee schedules are decreased, it is increasingly difficult
to care for patients, who are your customers. It is also difficult
for our members to understand how Premera Blue Cross can decrease
fee schedules so dramatically while shifting administrative and other
costs to chiropractors, and then increase the premiums that we pay
as health plan purchasers.
• The WSCA Board
of Directors and staff have received hundreds of calls about Premera’s
decision to decrease the chiropractic fee schedule, and we have
been given a variety of explanations of these changes from your
staff.
As a consequence, we
are requesting written responses to the following issues/questions
to help us properly inform our members about your policy:
1. Can you describe
the reasons and methodology used to make the decision to reduce
chiropractic reimbursement? Have you applied this methodology to
fee schedules of other health care practitioners? If so, which health
care practitioners?
2. Have you imposed fee schedule reductions to other health care
practitioners for similar or same services? If so, which health
care practitioners and services?
3. How do you handle chiropractic fee schedules compared to other
health professions? How do the reimbursement rates compare to the
same or similar services delivered by other provider types, and
how do those comparative rates match actual care delivery costs
ratios as described in RBRVS? If different, how are they different,
and what is the purpose and rationale of the differences? Is there
data to support any determined differences?
4. What is the impact of chiropractic services on overall premiums
costs; e.g., what percentage of premiums and/or premium fee increases
is due to chiropractic service costs? What reductions were made
to premium cost drivers having a greater impact than chiropractic
services?
5. If the chiropractic fee schedule reduction was in response to
a drive to open a closed chiropractic panel, what is the relationship
between panel opening and the reimbursement rate reduction? What
data supports that determination?
6. If the purpose was competitiveness in the marketplace, what alternatives
were investigated other than the chiropractic fee schedule reduction?
7. Has Premera investigated any system-wide cost savings (e.g.,
reduced pharmaceutical, surgery, or physical therapy) as a result
of opening and expanding chiropractic participation? If so, what
were the results of that investigation? Increased pressure from
large employer groups such as Microsoft would seem to suggest increased
demand by their employees for such services, a demand likely driven
by more effective care delivery by chiropractors for problems alternatively
managed with more expensive and invasive directions otherwise.
As you know, the WSCA has made every
effort to work with Premera Blue Cross in a professional relationship
over the past several years. As “partners” in providing
in-demand and cost effective health care, we are disappointed that
Premera chose to not inform the WSCA prior to a mass notification
to its members, or otherwise work with the WSCA in helping meet
mutual needs. We are also concerned that the recent action by Premera
suggests the perception that chiropractic care is significantly
driving up health care costs compared to the costs impact of other
health care practitioners caring for similar cases, complaints,
and health conditions. We are more concerned that fee reductions
for chiropractic may be wholly or partly arbitrary.
It is the intention of the WSCA that
we return to our previous methods of communication. We are hopeful
of honest, up-front communication with Premera regarding major changes
affecting future contracts and chiropractor working relationships.
We need time and information to understand and adjust to change.
We also need to know your rationale for change before implementation
so that we can educate and respond appropriately. Without this cooperation
we cannot offer Premera competitive alternatives that help both
of us. One study, included for your reference, shows that patients
with chiropractic care were less costly to their health plan than
those without. The WSCA would appreciate comment on your experience,
and if it is in agreement with the enclosed study, or not.
We look forward to your reply.
Sincerely,
William Davis, DC, DACS
WSCA President
cc: Mike Kreidler, Insurance Commissioner
John Conniff, Attorney at Law
Rich Maturi, Vice President Health Care Delivery Systems
Jack McRae, Vice President of Government Affairs
Karen Vogle, Account Executive, American WholeHealth Networks