EP469 (Part 2): The Impact on Plan Sponsors of Medicare Site-Neutral Payments and HSA Reforms, With James Gelfand, JD
Episode Description
In Part 2 of Episode 469, host Stacey Richter discusses the implications of Medicare site-neutral payments and Health Savings Account (HSA) reforms with James Gelfand, president and CEO of the ERISA Industry Committee (ERIC). The episode details how plan sponsors should adapt to Medicare's site-neutral payment policies aimed at curbing hospital consolidation and inflated prices through facility fees and markups. Gelfand provides insights into how HSA reforms currently in Congress could expand the scope of preventive care covered before deductibles are met, benefitting both employers and employees. The conversation also touches on the challenges high-deductible health plans pose and the potential benefits of codifying recent IRS guidance to allow greater flexibility in pre-deductible coverage. The discussion underscores the importance of plan sponsors staying ahead of Medicare policies to avoid higher costs.
WHAT YOU'LL LEARN
✅ What Medicare site-neutral payment policy actually means, and why it's designed to stop hospitals from charging a facility fee markup simply because a service happens to be delivered on a hospital campus rather than in a physician's office
✅ Why the site-neutral push is starting narrow — and what action steps plan sponsors should be taking now to align their own contracts with where Medicare policy is headed, rather than waiting for it to catch up to them
✅ What options plan sponsors have in highly consolidated markets where there may be no non-hospital-owned alternative to steer members toward
✅ How the proposed HSA reform bill could change pre-deductible coverage — expanding what preventive care can be covered before a member hits their deductible
✅ Why the thinking behind HSA usage has shifted since their inception, and why codifying recent IRS guidance on pre-deductible coverage would give employers more flexibility without abandoning the high-deductible plan structure entirely
WHY THIS MATTERS
Site-neutral payment reform and HSA modernization are both, in Gelfand's framing, catch-up plays — policy trying to close gaps that self-funded plan sponsors have been absorbing the cost of for years. The plan sponsors who benefit most from these changes will be the ones who understand the mechanics well enough to align their own contracting and plan design ahead of the regulatory curve, rather than reacting to it after the fact.
MENTIONED IN THIS EPISODE
EP471 with Christine Hale, MD, MBA: Apple Podcasts | Spotify | Other Apps
EP371 with Erik Davis and Autumn Yongchu: Apple Podcasts | Spotify | Other Apps
EP448 (Part 1) with Shawn Gremminger: Apple Podcasts | Spotify | Other Apps
INBW41 with Stacey Richter: Apple Podcasts | Spotify | Other Apps
=== LINKS ===
🔗 Show Notes with all mentioned links: Episode Page
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00:00 Introduction.
05:42 What does Medicare site-neutral payments mean?
08:59 How do markups play into the dynamics here?
09:52 Upcoming episode with Christine Hale, MD, MBA.
10:36 What does the "narrow" start for these changes mean?
11:42 What action steps should plan sponsors be taking?
13:01 What options do plan sponsors have in highly consolidated markets?
15:46 Will this bill potentially make changes to HSA plans?
17:40 Why has the thinking behind healthcare usage changed since the inception of HSAs?
23:24 How are preventive care and first-dollar coverage connected within the context of HSAs?
25:48 Why would it be difficult to completely get rid of a high-deductible health plan and offer HSAs without them?













