Article
What happened
On Aug. 31, the American Hospital Association commented on a set of draft issue briefs from the National Association of Insurance Commissioners’ Health Care Affordability and Mitigation Working Group. The briefs are meant to guide state regulators and lawmakers as they weigh options such as reference-based pricing and provider payment rate reductions.
The hospital argument
The AHA made three main points.
- Measure total burden. Affordability should reflect premiums, deductibles, cost sharing and possible out-of-network bills together, plus whether patients can reach covered services and in-network providers. Regulators should also ask who keeps the savings and whether costs simply move elsewhere.
- Weigh tradeoffs. Each option should be judged on benefits, limits and unintended effects, not projected payer savings alone. Payment cuts may lower one payer’s spending in the short run while straining hospital finances, workforce and service lines, especially in rural and underserved areas where losing obstetric, behavioral health or emergency care has outsized effects.
- Look at plan practices. Benefit design, narrow networks, utilization management and claims handling all shape what patients pay and whether they get care. High deductibles can lower premiums yet leave patients with bills they cannot pay.
The letter also pointed to administrative waste. Citing its March 2026 cost report, the AHA said hospitals spent an estimated $43 billion in 2025 trying to collect payment for care already provided, including about $18 billion spent overturning denials.
Why this matters for leadership teams
Insurance commissioners shape commercial rate review, network adequacy rules and other policies that affect hospital revenue. Briefs written now can become the reference point for state legislation next year. Reference-based pricing in particular can leave patients with balance bills and hospitals with payments below cost.
How to engage
- Know your commissioner. Find out whether your state’s insurance department is active in the working group or pursuing its own affordability agenda.
- Bring evidence. Prepare figures on denial rates, collection costs and patient out-of-pocket balances by payer.
- Show access effects. Be ready to explain which services would be at risk under specific payment cuts.
- Coordinate. Align messages with your state hospital association so regulators hear a consistent case.
Archive entry for Sep 6, 2026, added Nov. 11, 2026.