Thursday, 23 February 2017

Price Cap Order, Profit Disorder

Health care system, in general, is an imperfect world. We face notorious difficulties in measuring health care inputs and their associated outcomes at all levels of health care. Drawing conclusions about the interventions, their use and whether the healthcare inputs and outcomes give value for money is a major challenge. The recent NPPA order ((F.No. 19(837)/2016/Div.II/DP/NPPA, dated 02 Feb 2017) of fixing a ceiling on stent prices based on the contention that margins were exorbitant and irrational, an act of vulgar profiteering at various levels including the hospitals and cardiology clinics, raise a variety of economic and ethical arguments in the health financing sphere. Interestingly the order further states that the levels of margins indicate a “failed market system” where asymmetry of information has resulted in unethical practices. We are, may be, seeing one of the first crisis to be followed by much more such situations in future.

The hospital associations have contended that the margins charged are justified at their end as they are required to invest in capital assets to ensure a smooth running of operations. There are apprehensions that this will not work, and also put the consumers at a lot of inconveniences. The NPPA has argued that since hospitals are not doing any value addition, they must not be allowed to put any top-up margins and disassociate themselves from such practices. The NPPA order brings one of the central rallying cries in the health sector to a center stage. It brings forth, the debate about the influence of “business” on health care and the question of medical ethics. At most times, such discussions can become frustrating and controversial. But the positive side of this discussion being stated in clear terms is to give an explicit recognition to the fact that medicine and business are now connected, and there is something wrong. Asserting these linkages are inescapable because they are more visible now and at times turn to be uncomfortable to many stakeholders in the health system. The economic and ethical dilemmas are so pervasive; we cannot remain on sidelines any longer. I think this discussion will pave the way to argue about what kind of system we want in future.

Within the overall system, hospital market has its challenges, and it is important to understand the characteristic of this market in the background of debate on the cap on pricing. One of the characteristics on which the markets are typified is whether they are contestable. Contestable markets are one that has no exist/entry barriers. If in that market prices increase much beyond the average price level (and generate excess profits), potential rivals will enter the market to exploit this situation. The existing players will respond by bringing down the prices appropriate to yield normal profits. The perfect contestability will make it sure that even a single player can exhibit competitive behavior. Hospital care markets are not perfectly contestable as there are huge sunk costs creating huge barriers for exit and entry. It is difficult to find a suitable buyer of assets of hospitals once it is discovered the hospital is not doing well. Compounded with this is the fact that decision to use a particular input is decided by the doctor and not the patient leading to a situation of information asymmetry between doctors and patients leading to a situation of supplier-induced demand. Many of unpredictable implications of hospital practices may be traced to these problems. For example, hospital practices are replete with assertions that fee for service increases discretion and unnecessary clinical interventions. Given the contestability issues even having a large number of players, the competition will not necessarily lead to efficiencies and good practices. In private health care settings, in particular, the ability to pay takes precedence over the need and hospital pricing policies give dominance to business interests over health care. We have yet to experience the prescription of generic drugs, rather than the prescription of prescribing of expensive branded ones, with no significant benefit in patient outcomes. The response from regulators is inevitable in such situations. One of the typical responses from the regulatory toolbox is being following the dictum of “illegalization of dubious pricing” policies of providers.

However, one also needs to understand that here we are dealing with a situation where we have no data based on which one can make informed choices. Our costing systems are not good enough to help understand the relationship between inputs, activities/processes, and outcomes, in treatment pathways. There is no cost data available on such pathways. When hospital associations make a point that cardiac stents need a delivery mechanism to be implanted within the body and that the delivery mechanism and its ecosystem require capital investments, one wonders why these costs should be clubbed with the cost of stents. The detailed activity-based costing of hospitals is not in place, and one has no idea how much does an intervention costs. The cost information we have is related to functions such as salary, rent, etc., but it is not possible to find opportunity cost, for example, of an episode of hospitalization. Making this argument that stent prices are in fact within a bundled price of procedure and components weakens the argument. It reflects poorly on highly reputed hospitals as not having an appropriate costing system in place. It is high time for these institutions to invest in some basic infrastructure of financial management and understand their costs and present their arguments cogently. In recent times, most of the private and corporate hospitals have invested in hospital management information systems (HIMS) to manage patient care, finance, billing, medical records, and insurance clients. It is surprising that amidst such an IT infrastructure these hospitals fail to implement data collection mechanisms for calculating costs of treatment.

Some have argued that insurance companies pay for these procedures and the insurance providers routinely produce price data. It is important to understand that the price data produced by insurance companies are negotiated prices and may have little bearing on the real costs. The insurance prices data are many times bundled prices, and one does not know the cost of various components of the service.  We confront another challenge of not knowing the real outcome of various procedures, and there is no effort in place to capture this data. Often the outcomes are proxied with the process and the kind of stents used. This is certainly not the correct approach. The outcomes measurements should be based on the enhancement in duration and quality of patient's life or methods propagated by Prof Michael Porter on outcome measurement. In the private hospitals, there are huge gaps in capturing this information. Even if one captures some basic information such as readmission rates, it measures an important component of quality. The other point, which we also need to be confronted, is the high variation in costs and clinical activities across facilities in the country. Those working in the health sector recognize this fact, and there is little consensus on what is the best practice. In many situations, doctors do have good insights into the input-outcome relationships, particularly what is desirable and what is not desirable; however, they tend to ignore such knowledge because of perverse incentives. Doctors in many hospitals work based on “revenue target” approach, due to organizational pressures or third party paying system, thus creating moral hazard situations. Hospitals also work in highly fragmented markets and the same is true with their procurement side. This fragmentation increases costs, as one does not get an advantage of economies of scale.

The current debate also raise a wide variety of ethical arguments about health care financing; chiefly (a) what is the role of health and its distribution in society in advancing universal health coverage? (b) what is the role of access to or utilization of health care in maintaining or improving the desired level and distribution of health among members of society? and (c) what is the role of public and private financing in ensuring ethically justified access to and utilization of health care by members of society? The health care financing experience around the globe may have something to contribute to the development of the ethical foundations of health care system. For example, it is important that our policy deliberates on instituting systems that focus on ensuring “just” distribution of health care resources and strengthening the effort through good economic analysis of health care financing issues, health care provider incentives, health insurance markets and deliberating on the role of public and private financing in health care.

Indian health system needs to be ready to solve many crises to overcome in trying to create a healthy society for its inhabitants. As some say that the first crisis is always the crisis of not having a vision.


Ramesh Bhat
23 February 2017

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