Surprise Medical Billing Hearing
March 12, 2021
Page 4
And though some uncompensated care cost is reimbursed through disproportionate share and low-income
pool appropriations, these dollars are directed exclusively to brick and mortar hospitals, and not frontline
providers and groups.
And though emergency physicians currently treat roughly 5 of 10 uninsured and indigent patients, there are
no programs that deliver us a comparable offset for our services.
Presently, uncompensated care along with reimbursements from low payers like Medicaid and Medicare
are offset and cross-subsidized by a range of in and out-of-network commercial payers, yielding our current
economic market equilibrium in Michigan. But as noted, these amounts will quickly begin to drop by 20%, or
so, unless the administration uses its authority to craft some guardrails moving forward.
We believe implementing rules as we submitted are within the administration’s authority and spirit of the
Michigan Surprise Billing Act. Nothing within our proposed rule amendments is prohibited by the Act, in
fact, encouraged, as demonstrated by statements of “including, but not limited to…” Specifically, Public Act
234, of 2020, allows the department to promulgate rules for two sections addressing the following:
First: Median in-network rates, and
Second: Complicating factors.
Moreover, our proposed changes are equitable, and will help Michigan avoid undesirable and chaotic
outcomes for emergency care, while maintaining the level of services and sustaining the medical safety-net
Michiganders rely upon.
In closing, my focus is to deliver care to my patients. However, the vagueness of this Administration’s
Proposed Rules is alarming, and will likely lead to a downward spiral in emergency care. As an industry, we
are respectively asking the Whitmer Administration to find the way to modify your rules, and to include more
clear procedures containing, centering, excuse me, centering on median amounts and complicating factors,
like those we have provided here today.
Thank you very much.
Sarah Wohlford: Thank you. Belinda Chandler, are you indicting a desire to submit a public comment?
Belinda Chandler: Yes, I am.
Sarah Wohlford: Ok, please proceed. Thank you.
Belinda Chandler: Good morning everyone. My name is Belinda Chandler, and I am the Executive Director
of the Michigan College of Emergency Physicians. I would also like to thank the Whitmer administration,