HB 7115, An Act Concerning Revisions To The Health Care Cost Growth Benchmark Program

TESTIMONY OF THE CONNECTICUT HOSPITAL ASSOCIATION
SUBMITTED TO THE INSURANCE AND REAL ESTATE COMMITTEE

Thursday, March 6, 2025

The Connecticut Hospital Association (CHA) appreciates this opportunity to submit testimony concerning HB 7115, An Act Concerning Revisions To The Health Care Cost Growth Benchmark Program. CHA opposes Sections 3 and 4 of the legislation.

Connecticut hospitals and health systems care for patients, strengthen the state’s economy, and support vulnerable communities across the state. Every day, they work to improve healthcare access, affordability, and health equity. Even as they face ongoing challenges, hospitals provide world-class care to everyone who walks through their doors, regardless of their ability to pay. Hospitals also support an exemplary workforce as the largest collective employer in the state, contribute significantly to the state’s economy, and invest in their communities addressing social drivers of health.

Section 3 gives broad authority to the Office of Health Strategy (OHS) to use policies and procedures to implement the office’s statutory requirements. CHA continues to oppose the authorization by the legislature of agency use of policies and procedures to implement statutory requirements. Unfortunately, what are meant to be temporary requirements while regulations are crafted and implemented have become de facto regulations without the benefit of a robust public comment period or legislative oversight. By using policies and procedures to circumvent the formal regulatory process, agencies have become less accountable to the public and agency activities do not have the benefit of formal comment from experts outside the state government. State agency work is too consequential to continue the unchecked use of policies and procedures to implement agency business.

Section 4 requires OHS to submit a report to the General Assembly after it conducts an analysis of “health care benchmark performance improvement plans.” Last session, OHS sought authorization to impose performance improvement plans as part of the benchmarking process. That effort did not advance. While we recognize OHS’s continued interest in performance improvement plans and other mechanisms to penalize non-attainment of the benchmark, our underlying concerns remain. If the committee chooses to take action on
HB 7115, CHA respectfully requests the committee amend the bill to require OHS to include robust stakeholder involvement in its analysis and study.

Since last year, CHA and OHS have had the opportunity to discuss the data process OHS has developed to implement the benchmark. While we appreciate the opportunity to have those conversations with OHS, we believe there continue to be data process improvements that should be addressed before performance improvement plans or any other measure to penalize entities subject to the cost growth benchmark are considered.

Thank you for your consideration of our position. For additional information, contact CHA Government Relations at (203) 294-7301.