1、CDHPs + DM = Population Health?March 2006John Riedel MBA, MPH Vince Kuraitis JD, MBA Riedel May 19, 200423 Harris Interactive Survey HDHP Consumers Have More Compliance ProblemsSource: Harris Interactive, 2005 24 How Big a Deal is Adherence to Prescribed Treatments?“Increasing the effectiveness of a
2、dherence interventions may have a far greater impact on the health of the population than any improvement in specific medical treatments.” World Health Organization, 200125 HRAs vs. HSAs Have Vastly Different Implications For DM Health Reimbursement Arrangements (HRAs) allow employers more flexibili
3、ty to structure benefits that are “DM friendly”. Employers have the option to structure first dollar coverage for a wide range of benefits. First dollar coverage allows for employers to pay for specific services e.g., preventive care, DM, with pre-deductible dollars. HRAs provide a transitional appr
4、oach which is more appealing to larger, more sophisticated companies.26 Health Savings Accounts (HSAs) allow employers virtually no flexibility to structure benefits that are chronic care and/or “DM friendly”. The underlying philosophy of HSAs is focused on exposing employees to “true, full costs”
5、of health care. HSA regulations allow very limited flexibility for preferential benefit structures, e.g., benefit structures that provide first dollar coverage and/or incentives for DM or related programs. HSAs allow minimal discretion to differentiate coverage among different health care components
6、, e.g., Rx, hospitals, doctors, etc. HSA regulations do allow for first dollar coverage of preventive care. However, DM is not defined as preventive care. Employers generally view HSAs as a more potent CDHP vehicle because the savings feature encourages employees to view funds as “my money”.27 While
7、 Treasury Regs Require “Comparable” Contributions to Employee HSAs by Employers “Employer contributions to an HSA based on an employees participation in health assessments, disease management program or wellness program do not have to satisfy the comparability rules if the employee may elect to rece
8、ive that payment in currently taxable cash rather than having a nontaxable contribution to the HSA Cafeteria plan nondiscrimination rules also apply” Translation: Employers are allowed to fund DM for the 10% who need it only if they give an equal amount of cash to the other 90%28 President Bush is On Record Supporting Legislation to Allow Employers to Make Higher HSA Contributions to Chronically Ill Employees29 IV. Two Scenarios of How CDHPs and DM Come Together30
