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Health Commission tables patient-rate ordinance after questions on billing, bundled payments

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Summary

The San Francisco Health Commission on May 5 postponed action on the Department of Public Health's proposed patient-rate ordinance, directing staff to return May 19 with detailed explanations of how the rates were built, how bundled payments work for certain injectables, and how patient liability will be limited.

The San Francisco Health Commission on May 5 postponed a vote on the Department of Public Health's proposed patient-rate ordinance after multiple commissioners pressed staff for clearer explanations of how the rates were constructed and how commercial insurers and patients would be billed.

The commission voted to table the ordinance until May 19, 2025, after discussion about recent amendments and several unanswered operational questions.

At the meeting, Matthew Sir, Reimbursement and Revenue Cycle Director for the San Francisco Health Network, described three technical amendments: a change to the billing frequency and amount for injectable buprenorphine (SUBLOCADE) to match a CMS change from weekly to monthly administration; a price update for injectable naltrexone (Vivitrol); and a shift at Laguna Honda Hospital from historic 'all-inclusive' rates to line-item billing. Sir said the department also proposed 2.67% and 2.82% rate increases in the two fiscal years to align with CPI guidance and Medi-Cal adjustments, and that DPH was adding rates for new BH Connect services and removing obsolete transportation rates.

The commissioners asked for more context on how the ordinance translates to actual payments. Commissioner Guggenheim asked how confident the department was that Medicare and Medi-Cal payment schedules would match the published rates. Sir said Medicare and Medi-Cal have their own fee schedules, and that adopted patient rates are one component of hospital billing; he added that DPH has limited commercial contracts and typically receives negotiated, customary payments from private insurers.

Commissioner Chao sought clarity about whether the clinic-level numbers in the packet were professional fees only or also included facility fees; Sir responded that the ordinance lists professional fees and that facility fees appear in a large separate price list. Commissioners also asked for CPT-code mapping, details on bundled services for injectable buprenorphine (Sir said the monthly HCPCS bundle can include dispensing/administration, substance use counseling, individual and group therapy and toxicology testing), and whether the listed rehabilitation and Laguna Honda rates were competitive with commercial rehab facilities.

Concerns about patient financial responsibility surfaced repeatedly. Commissioners requested clearer documentation on how patient-cap, sliding-scale charity care and other policies limit out-of-pocket charges when commercial insurers do not fully reimburse.

After the discussion President Greene proposed postponing the vote for two weeks to allow staff to provide a more detailed presentation addressing Commissioner questions; the commission voted to table the ordinance to the May 19, 2025 meeting.

What the commission directed and next steps - The commission voted to table action on the patient-rate ordinance and requested a follow-up presentation that includes: a clearer explanation of how each rate was derived; CPT-code mapping where feasible; how facility and professional fees relate in the packet; expected behavior from commercial payers; and how patient-cap and charity-care policies will limit patient financial exposure. - The department will work with the commission secretary and the Controller's office to provide supplemental materials before the May 19 meeting.

Why it matters Patient rates guide the hospital and clinic charge structure used to seek payment from Medicare, Medi-Cal and private insurers and inform how much the hospital bills uninsured or underinsured patients. Commissioners said they need better documentation so the public and elected officials can understand the real-world impacts on patients and on DPH revenues.

Votes and formal action - Motion to table the patient-rate ordinance until May 19, 2025: motion moved and seconded; outcome: tabled. (Recorded voice vote: ayes.)

Speakers quoted and cited - Matthew Sir, Reimbursement and Revenue Cycle Director, San Francisco Health Network (presentation of ordinance changes) - Commissioner Guggenheim (asked about Medicare/Medi-Cal matching) - Commissioner Chao (asked whether clinic numbers were professional fees)

Ending The ordinance remains on the commission's agenda with a tentative May 19 date for reconsideration once DPH supplies the requested financial and procedural clarifications.