Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207 #00018

Submission Number:
Jim Licata
Initiative Name:
Announcement of Public Workshop, "Examining Health Care Competition" ("Health Care Workshop") Project No. P13-1207
I have been a licensed optician in the retail prescription eye care profession for 42 years. I would like to thank the FTC for the opportunity to comment on some of these very important issues.I will keep my comments directed at how these issues relate to fair trade and competition in the Rx optical field. Your questions seem to be directed towards health insurance companies. I will answer a few. We have ever increasing regulations and contractual constraints added to our professional lives every day. Most of which are devised by health insurance companies. (Hereinafter noted as HICs).Claims, networks, credentialing, and fixed purchasing and reimbursement policies. These lower our ability to professionally focus on our patients ,financially meet the margins we need to stay in business and make a living. Over the years HICs have evolved into controlling every aspect of the healthcare industry. When you consider copayments, deductibles, formularies, coinsurance, in network, out of network, thousands of different policies, getting authorizations, performing the work, submitting claims, resubmission of denials and a myriad of other aspects to consider in a single persons policy, it has become an administrative nightmare. It's expensive and wastes time. Plus every HICs has it's own format. Claims. You want to cut costs? Find a single system and SIMPLIFIED claim process that all HICs must use. All HICs should have to use the same internet format when authorizing and processing claims. Networks. The biggest competitive constraint. My view is I am licensed by my state to serve everyone in my state, yet I am denied access to the very patients I am licensed to serve. In my opinion, because a HIC sells a program to someone does not give them the right to control commerce. It is unacceptable to me to turn people away because my business is not allowed into a network and that customer must go to a competitor. I am not in business to turn away people. And consider that millions of policies are purchased by the consumers employer and included when employed. What new employee would not accept an employers benefit package? That consumer now has to go where their HICs direct them. An end around by HICs to control a market. Competition lowers prices. Consumers are pretty savvy. They will shop for prices in healthcare like they do everything else. Solution, transparency. Make the HICs list exactly what they will pay for services and products and have the consumer make their own healthcare decisions. Credentialing. I have no problem with licensure, pretty much all states require licensing. It is the states job to make sure that each professional is licensed and documented, therefore I see no reason for HICs to require credentialing. All they need to do is contact the states licensing divisions, have the professional send a copy of their current liability/malpractice insurance and done. The State should have all the information necessary for the HICs to verify a professionals standing. In my opinion it is not the HICs place to police the professions. This would alleviate the time consuming process and waiting period of credentialing. Fixed purchasing and reimbursement. Here's a newer one and this one beats them all. Under contract, to have access to members, I must buy my products at a higher price from suppliers designated by the HICs and sell that product to the member at the designated lower price. Now if that's not a restraint of trade, I don't know what is. They have effectively ruined business relationships that have taken me years to develop. Years of negotiating and finding the best prices from the most competent and experienced people in the industry for my patients are gone. The work is subpar and it takes longer to process. This puts me at serious competitive disadvantage. The healthcare industry needs to be restrained and it will need to be micro managed. Thank you FTC for looking into these matters. Please do it soon.