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Washington State Chiropractic Association
21400 International Blvd. Ste 207
SeaTac, Washington 98198


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
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