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the House saw fit to so preserve the independence of all physicians including radiologists, pathologists, anesthesiologists and physiatrists. I am now concerned that the Senate may be swayed by an attempt by the American Hospital Association to reclassify the services of the physicians in these four specialties as hospital services.

Hospital radiologists and physician members of the other three specialties need and deserve independence from hospitals in which they must work (as must surgeons and most all other types of physicians) for the benefit of their patients, their specialties, and themselves. It is true that some such physicians practice on a salaried basis in hospitals, but so do other types of physicians such as surgeons. The vast majority of the physicians in the four specialties the AHA would like listed as hospital services practice under a contract, fee for service basis and a significant number actually bill independently. Unfortunately, except in those instances where such physicians do bill independently, hospitals have increasingly through the years profited on the services of such physicians, this fact being the basis for the desire of the hospital industry to reverse that part of the House bill dealing with radiologists, etc. It is important to realize that this same situation, in addition to frequently being the cause of a lowering of quality of "hospital-professional" services by encouraging a high volume of patients per physician in a monopolistic situation, is also responsible for a decrease in the attractiveness of such important fields to graduating medical students and interns. The specialty of radiology for example is currently seriously falling behind demand in the training of residents and the fact of hospital indenture is unquestionably a major factor. There is no question in my mind that I would have chosen a field other than radiology 12 years ago had I known that it might become a branch of medicine designated in law as a "hospital service".

There is no basis for any fear by the AHA that the provisions of the current House bill would affect the continued development of the modern hospital system. The provisions of the bill would appear to be such that the hospitals would be reimbursed completely for all their costs including equipment replacement and financing of newer, more advanced facilities. Radiologists recognize the need of hospitals to do this and also know that above and beyond these complete costs the hospitals have long taken from the patient without his knowledge an amount equal to 10 to 20 percent and more of the fees in radiology, for example, to cover hospital deficits outside the X-ray departments. Patients are thereby forced to pay for services they may not request or need. Might it not be better for hospitals by careful cost accounting encouraging more efficient management to show true costs of all phases of hospital operation in billing the patient or Government for those services actually supplied each patient?

The nationwide renegotiation of contracts which it is said will be necessary by hospital spokesmen will not be required. For patients covered under the current medicare bill, the hospital will simply receive their cost from the Government and the radiologist, etc., can simply and easily bill separately for his professional services. It should be realized that this may very well bring about a reduction fees in these specialzed services by the amount that the hospitals have for year profited from them. Where certain specialists are on a salaried basis, they could simply assign the payment for their professional services to their employer. After all, what will the hospital system plan to do in the case of employed surgeons in addition to other physicians outside the fields of radiology, pathology, anesthesiology and physiatry?

I respectfully request that you consider the points I have raised above and hope that the Senate Finance Committee will resist the efforts of the American Hospital Association to change the current medicare bill to wrongly classify radiology and these other three specialities as hospital services.

Yours very truly,

WILLIAM R. LETSCH, M.D.

HINKLEY & DONOVAN,

ATTORNEYS AT LAW,

Hon. NORRIS COTTON,

U.S. Senate, Washington, D.C.

Lancaster, N.H., April 20 1965.

DEAR SENATOR COTTON: Regardless of the merits of the medicare bill, I am very much opposed to section 303 thereof relating to social security disability benefits.

This section seems to me to have nothing to do with medical care and will be a further encroachment upon State workmen's compensation laws. You, of course, are aware that already there is some encroachment in case of total disability and section 303 would extend this encroachment by providing social security benefits where the disability is more than 6 months.

In a great many instances, disabled workmen will be receiving more in total benefits than they were able to earn and obviously their incentive to return to useful employment will be greatly reduced.

I hope you will do what you can to delete section 303 from the bill.
With best regards, I am,

Sincerely yours,

WALTER D. HINKLEY.

NEW HAMPSHIRE INSURANCE CO.,
Manchester, N.H., April 19, 1965.

Re H.R. 6675-Social Security Amendments, 1965-duplication of compensation insurance and social security benefits.

Hon. NORRIS COTTON,

U.S. Senate, Washington, D.C.

DEAR NORRIS: For some years a highly inequitable situation has existed under which certain persons who were totally and permanently disabled could collect legally prescribed compensation insurance payment from their employers' insurance companies, and in addition collect benefits for the same injury under the Social Security Act.

Many evils result from this. For example: (1) It discriminates against those who are not entitled to compensation; (2) it places a premium on permanent total disability since the total recoveries exceed wages in many States; (3) it constitutes an encroachment of Federal Government into the insurance business; (4) it furnishes another of the many ratholes for spending taxpayers' money where no such spending is justifiable; (5) it results in two compulsory systems providing benefits for the same injury. Now suddenly and without warning it is proposed to broaden social security benefits to add to the total permanent disability, temporary disability lasting 6 months or more, still with no offset of compensation benefits.

This, therefore, would further worsen the situation.

I strongly urge that the broadened definition of disability under the above bill be eleminated, or an offset of compensation payment provision be incorporated in the bill.

Sincerely,

Clark.
CLARK B. BRISTOL.

STATEMENT OF CALIFORNIA COMMISSION FOR THE ACCREDITATION OF NURSING

HOMES AND RELATED FACILITIES

Pending legislation reflecting the increased concern of the Federal Government with long-term medical and/or nursing home care for patients over 65 years of age contains provisions relating to means of determining quality of performance in long-term facilities. The mechanism of accreditation may be proposed as a means of identifying facilities to which payment may be made. You may realize that accreditation programs for nursing homes and related facilities at the national level are still somewhat unsettled. It is widely agreed that two agencies performing essentially the same function is not only redundant but may even be deleterious to the concept of voluntary accreditation. Undoubtedly amalgamation of the national accreditation programs will come about within a reasonable time, as soon as reconciliation of certain philosophic differences can be attained.

I would like to point out that California already has an accreditation program for nursing homes and related facilities operative for more than 4 years, sponsored jointly by the agencies in the State whose counterparts are failing to agree nationally. We believe that California represents the nidus from which consolidation may develop at the national level.

I would respectfully request, therefore, that the wording of the final bill concerning patients needing care in nursing homes be such that the California Commission for the Accreditation of Nursing Homes and Related Facilities

might qualify as the accrediting agency in this State until such time as a single broadly based accrediting body is operative nationally.

The commission was organized in March 1961 as a voluntary, nonprofit association. Its inception was prompted by the fact that the medical and dental professions, hospital adminstrators, and nursing home administrators felt the need for high standards of care to which nursing homes could subscribe. It is an effort to improve the care of the patient in nursing and convalescent homes. The major purposes of the commission as stated in the constitution is as follows:

"To conduct a survey and accreditation program which will encourage the establishment and improvement of nursing homes and related facilities; and to establish and apply certain basic principles of organization and administration for efficient and kindly care of patients/guests of nursing homes and related facilities."

The membership of the commission consists of two representatives each from the California Medical Association, California Hospital Association, the California Association of Nursing Homes and one representative each from the California Dental Association and the Southern California State Dental Association. The commission is supported financially by contributions from the member organizations plus fees received from nursing homes and other related facilities requesting survey and accreditation.

As of March 31, 1965, a total of 252 requests for initial survey and accreditation had been received. Twenty-five nursing homes have been denied accreditation as not meeting the standards of the commission. Twenty-two have allowed their accreditation to lapse. In addition there are applications awaiting initial survey. To qualify for survey by the Commission a facility must have been in operation under the same ownership for a period of at least 6 months. It is the feeling of the commission that this is the minimum period of operation which will permit a true evaluation of the quality of care in a facility.

Nursing and convalescent homes are furnished with full preliminary information of the standards of the commission and the requirements for accreditation. Inasmuch as the major objective is to improve the care of the patient and quality of care, the commission feels that its function is educational as well as accreditation. Facilities are furnished with self-evaluation questionnaires which permit them to find their weak spots and correct them before applying for accreditation.

Accreditation is purely voluntary on the part of the facility. Application accompanied by a fee of $60 plus $2.50 for each licensed bed must be made to the commission. A careful survey of the institution is then made. The report of survey is examined by all members of the commission and if approved a certificate of accreditation is issued to the facility. The licensing agency is then notified of the accreditation as is also Hospital Service of California, Hospital Service of Southern California, California Physicians' Service and interested commercial insurance companies which may write health insurance for care in convalescent hospitals.

Accreditation is for a period of 2 years from the date of survey and is not automatically renewed. For continuation of accreditation during the next 2year period request must be made to the commission. A full survey is made and the report passed upon by all members of the commission as in the initial survey. Provision is made in the bylaws whereby interim surveys may be conducted if there is a reasonable report or belief that the facility is not continuing to meet commission standards of accreditation. If this interim survey reveals major deficiencies or serious substandard operation, accreditation is withdrawn. The facility is then ineligible for accreditation for a period of 6 months and must file formal application for survey if they wish to become accredited. There is also provision for appeal and hearing before the commission. In establishing criteria for nursing and convalescent homes which may be reimbursed for the care of individuals covered under health insurance, Hospital Service of California and Hospital Service of Southern California (Blue Cross) have indicated in their policies that facilities which have been accredited by the California Commission for the Accreditation of Nursing Homes shall be deemed to have met their criteria. Western-65, includes accreditation by this commission as a minimum requirement for a nursing or convalescent home to be qualified to receive payment under their policies. Other commercial companies. writing insurance for nursing home care accept accreditation as an indication that a facility meets their requirements for payments.

The nursing homes that are accredited or applying for accreditation are about equally divided between northern and southern California. They extend from Alturas on the north to Indio on the south. The great majority are in the areas adjacent to Los Angeles and San Francisco.

The first survey was conducted in September 1961. As of April 1, 1965, there were 196 nursing homes on the accredited list, representing 11,843 beds. This is 19 percent of the 1,025 licensed facilities in the State and 27 percent of the 43.227 beds.

The program of accreditation by the commission has been publicized widely to all nursing and convalescent homes in the State. As the program becomes better known, more and more nursing and convalescent homes are seeking accreditation. It is noted that physicians seeking a facility for convalescent care for a patient are giving preference to those facilities which have met the standards of this commission. The standards for accreditation are rigid but it is the feeling that such is necessary in order to promote a high quality of care in all of its aspects to the patients in nursing and convalescent homes that they may obtain the greatest benefits offered by medical and nursing science.

In all fairness to the more than 19 percent of facilities in California which have maintained high standards of care and in view of the unity of purpose of the member agencies supporting the commission it is respectfully requested that if an amendment requiring accreditation is introduced that the final wording of the amendment be such that the California Commission for the Accreditation of Nursing Homes and Related Facilities be allowed to qualify as the accrediting agency in this State until such time as a single broadly based accrediting body is operative nationally.

COUNCIL OF LOUISIANA BUSINESS AND TRADE ASSOCIATIONS,

Baton Rouge, La., May 1, 1965.

Re H.R. 6675, Social Security Amendments of 1965.

To the CHAIRMAN, HON. HARRY F. BYRD, and MEMBERS OF THE SENATE FINANCE COMMITTEE,

U.S. Senate,

Washington 25, D.C.

GENTLEMEN: Without a public hearing before the House Ways and Means Committee, H.R. 6675 passed the House of Representatives on April 8, 1965, and is now under your consideration. According to press notices only those employer representatives who have previously arranged for appearances will be heard by your committee.

Respectfully submitted, however, is the position of Louisiana Business, coordinated and endorsed by the business and trade associations named herein, regarding H.R. 6675, Social Security Amendments of 1965. It is urged that a copy of such position be made available to each member of the committee and to the Congress of the United States.

POSITION OF LOUISIANA BUSINESS ON H.R. 6675

Only the vaguest idea of the enormous scope of this bill, designed within the House Ways and Means Committee in executive sessions and with no public hearings, has been made known to the American public. As an example of this, on national television and in the national press, this 298 page document has been called very simply the medicare bill. Such news media have quoted the administration as stating immediately after its passage by the House: "Thirty years from now you will realize the benefit of the historical passage of this medicare bill."

Yet, the report of the Committee On Ways and Means to Congress gives the overall purpose in these categories.

(1) To provide a coordinated approach for health insurance and medical care for the aged under the Social Security Act, etc.;

(2) To expand the services for maternal and child health, crippled children, and the mentally retarded, and to establish a 5-year program of special project grants to provide comprehensive health care for needy children of school age or preschool age;

(3) To revise and improve the benefit and coverage provisions and the financing structure of the Federal old-age, survivors, and disability insurance system, etc.

Obviously, it would be quite difficult for the American public to have the slightest idea of the enormity of this bill even after reading the 264 page committee report on the 298 page bill.

Nevertheless, Louisiana Business believes that in all fairness to the American people, at least the following highlights of the scope of this legislation should be emphasized nationwide.

SYNOPSIS OF SCOPE

I. Health insurance and medical care for the needy

A. A basic plan providing protection against the costs of hospital care financed through a new and separate payroll tax and a new and separate trust fund.

The new tax.-This new tax begins at 0.7 percent of payroll and increases to 1.6 percent of payroll, divided equally between worker and employer. The tax base is increased from $4,800 per annum to $6,600 per annum. The $200-permonth worker and his employer each will pay $38.40 per year and the $550-permonth worker and his employer will be taxed $105.60 per year. Yet, the benefits will be exactly and basically the same for each worker as in the medicare proposals of former years.

Unless a hospital agrees to follow all of the regulations and price tags placed on it by the Federal regulator, it will not be licensed as a provider, and these services would not be available there under that plan. There are, of course, a number of regulatory measures aside from this bill which the Federal Government could invoke to force institutions to become providers.

The cost. This is, of course, a reestimate of the popular slogan, "For less than 3 cents a day, etc." The tax in this bill for some workers and their employers is 29 cents per day, which is about 10 times the original slogan used to popularize prior medical plans. A worker and his employer together will pay $105.60 per annum toward hospitalization cost of those 65 and over.

According to the Federal Department of Health, Education, and Welfare (p. 252 of the report of the Committee on Ways and Means to Congress) the cost of providing hospital benefits to those now 50 years of age or over is $140 billion. Those 50 years of age or older will contribute not more than $7 billion for their benefits.

Accordingly, the Federal Department of Health, Education, and Welfare concludes that

The cost that younger workers will be required to pay to provide benefits to those now 50 years of age or over is $133 billion (p. 252).

The committee report further states (p. 251), "The actual cost of the hospitalization program per workers entering the work force at age 21, with interest at 31⁄2 percent per annum, will amount to $8,590.”

That worker, meanwhile, during all of his working years, has the responsibility of self-insuring the health needs of his family and himself out of his own earnings.

B. The second portion of the coordinated approach for health insurance under H.R. 6675, has to do with a voluntary supplementary plan providing payments for physicians and other medical and health services financed through small monthly premiums by individual participants and matched equally by the Federal Government out of general revenues.

Premiums.-Participant would put up $3 per month and Government would put up $3 per month out of general revenues. These funds would be placed in a government trust fund, from which the insurance companies would be paid. Here, again, the Federal Secretary would determine which insurance companies could participate and be permitted to enter into a Federal Government contract. Benefits.-There would be a $50 annual deductible. Then the plan would cover 80 percent of the patient's bill for physician and surgeon services; home health services, diagnostic X-ray, laboratory, electrocardiograms, and other tests; ambulance service, surgical dressings, splints, cast, iron lungs, oxygen, wheelchairs, artificial limbs, etc.

The $3 per month premium of the individual would be deducted from current social security benefit, if any. The committee report (p. 6) specifically notes that since social security benefits are at the same time being increased by at least $4 per month, such increase would more than pay for this premium.

COMMENTS ON MEDICARE PORTION OF H.R. 6675

Each member of the Senate Finance Committee was furnished on November 25, 1963, the position of Louisiana Business on medical care for older citizens.

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