Mid-Texas Health Care Issues Public Comment on IRS Proposed Rule

WASHINGTON, July 27 -- Karen Swift, billing manager at the Mid-Texas Health Care, Fredericksburg, Texas, has issued a public comment on the Internal Revenue Service's proposed rule entitled "Certain Medical Care Arrangements". The comment was posted on July 24, 2020:

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I am grateful the government is moving to allow citizens greater control over their Health Savings Account (HSA) dollars. Adding Direct Primary Care (DPC) medical services provided by doctors is long overdue as an HSA Qualified Medical Expense. Persons with a health share should also be allowed to participate in a HSA since they are typically required to pay in full for medical care at the time of service, similar to someone with a HDHP.

In a system that has grown over decades to a dizzying size and complexity, subscribing to a local doctor for medical services creates a simple path for patients to get immediate low cost care.

However, there is a Trojan horse in the rule. By identifying Direct Primary Care as a health plan, the rule opens the door to an avalanche of regulatory control. The reason Direct Primary Care works so well for doctors and patients is that it opts out of these layers of bureaucracy. Direct Primary Care is health care NOT a health plan.

By defining Direct Primary Care medical subscription services as a health plan, it opens these independent doctors offices across the nation to the regulatory control of State insurance commissioners.

Direct Primary Care is NOT ARISK BEARING ENTITY. It is an agreement to provide health care services provided by a doctor to a patient. Patients must continue to maintain health insurance for catastrophic care something outside the scope of the local doctors office (and Direct Primary Care).

The old adage, an ounce of prevention is worth a pound of cure, is the sweet spot for Direct Primary Care. By maintaining the business freedom of Doctors, Direct Primary Care is a medical service that is incentivized to provide high-quality care for the lowest price the market will bear.

80% of all health care issues can be resolved through a local doctors office. Patients who see a DPC physician have a +40% reduction in ER utilization and a +19% reduction in hospitalization.

NO further regulation is needed beyond that already provided by State licensure, OSHA, standards of care enforced via malpractice law, etc.

Using HSA dollars for medical service subscriptions is a private business partnership between a patient and their doctor.

Please DO NOT define Direct Primary Care as a health plan.

Please DO NOT put limitations on how the HSA dollars are spent beyond going to licensed health care providers.

Please ALLOW personal contributions to HSAs when a patient has a Direct Primary Care doctor. Under the current rule, Direct Primary Care is considered a second health plan and thereby patients are prohibited from making their own HSA contributions which is self defeating for the goal of the rule expanding low cost, high-quality care to rural and underserved communities.

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The proposed rule can be viewed at: https://beta.regulations.gov/document/IRS-2020-0016-0001

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