Collaborate with Clients to Comply with the MA HPC

The Situation

Mintz regularly represents clients before the HPC regarding a variety of HPC initiatives. The HPC requires certain providers and carriers to file a Notice of Material Change prior to consummating certain transactions, such as clinical affiliations and alignments, mergers, and acquisitions. 

The Approach

We assist clients in preparing the Notice, and working through the review process with the HPC. Following review of the Notice, the HPC may decide that the proposed change is anticipated to have a significant impact on health care costs or market functioning, in which case it will want to conduct a Cost and Market Impact Review (CMIR). We coordinate with transactional lawyers and other business and financial advisors throughout the review process.

The HPC conducts annual Cost Trends Hearings at which health care executives, industry leaders, and government officials may be asked to testify. At the hearings, the HPC brings together state and national health care experts to examine the state’s performance under the Health Care Cost Growth Benchmark, the drivers of health care costs, and other health care reform efforts. We help prepare health care executives and leaders for their testimony and hearings.

Finally, Mintz helps clients, including complex, multistate provider organizations, comply with the requirements of the MA-RPO Program, a joint program of the HPC and the Center for Health Information and Analysis (CHIA). The MA-RPO Program incorporates the required data elements of both the HPC and CHIA in a single, annual filing. We assist provider organizations in determining what information is responsive to the MA-RPO filing requirements, and work with the HPC counsel and staff, as necessary, to resolve questions and assure timely, complete filings.