Hospitals, insurers debate 'site‑neutral' billing; Blue Cross offers physical‑therapy savings estimate

Health Care Committee · February 25, 2026

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Summary

Hospital and insurer witnesses told the committee that narrow site‑neutral billing could align with reference‑based pricing but needs clear transition language; Blue Cross cited an $85 professional fee vs. $400 billed example and estimated $3–$6 million in statewide savings on physical therapy for its members.

Devin Green of the Vermont Association of Hospitals and Health Systems told the Health Care Committee that narrowing the proposed site‑neutral language reduced the potential immediate impact on hospitals and offered the panel an opportunity to study the change's effects.

"Neutral," Green said, "means different things to different people," and urged the committee to consider transitional rules if reimbursements are to 'sunset' once reference‑based pricing is implemented. He asked for clarity to avoid undercutting ongoing reference‑based pricing efforts.

Courtney Harnett of Blue Cross and Blue Shield of Vermont provided a concrete billing example: a professional fee near $85 that was billed by a hospital outpatient location at about $400. Harnett said that consistent billing could narrow that variance and that Blue Cross could provide written data. "We could see be anywhere from, like, 3 to $6,000,000 in savings on a physical therapy line of service for Blue Cross and Blue Shield members, statewide," she said, and offered the committee written testimony with hospital‑by‑hospital fee schedules to support the estimate.

Committee members asked whether site neutrality would lower premiums or shift costs; witnesses and insurers said the immediate actuarial value would change little but that benefit design might give consumers more plan options. The committee requested polling of hospital members, modeling on uncompensated care impacts, and written data from insurers before advancing any statutory changes.