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Providers back association health plans and site‑neutral billing as relief for independents
Summary
Nonprofit advocates, independent clinicians and an independent practice association told the Senate Finance Committee H.585's association health plans and site‑neutral billing could expand coverage options and stabilize small providers, while urging guardrails and phased design to avoid adverse selection and protect hospitals' financial stability.
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Several witnesses before the Senate Finance Committee on April 8 urged the panel to advance H.585 provisions that expand association health plans (AHPs) and create site‑neutral billing, while also recommending safeguards to manage risk.
Emma Paradise, co‑director of Common Good Vermont, said AHPs could make benefits affordable and predictable for nonprofits that struggle to offer coverage: “AHPs could really provide much‑needed relief to nonprofit employers and expand benefits to employees,” she told the committee, while cautioning the state’s small size could limit observed cost savings and urging guardrails against adverse selection.
Susan Ribson, executive director of Health First, said her association of more than 250 clinicians supports the House version of H.585’s AHP language and strongly backs site‑neutral billing. “Equal pay for equal work has been an issue we’ve repeatedly sought to remedy,” Ribson said, urging the committee to build a ramping mechanism so the policy can expand to additional code sets over time and to consider adding certain evaluation and management codes.
Michael Lansburg, an athletic trainer of 33 years, described how including athletic trainers alongside physical and occupational therapists in site‑neutral reimbursement would preserve access: he warned that without parity in reimbursement small clinics might not hire athletic trainers and that could reduce patient access. “If we don't get that same reimbursement, I think you're going to see organizations… would not hire athletic trainers,” Lansburg said.
Sharon Gutland, owner of the Rehab Gym and a longtime physical therapist, argued site‑neutral billing could slow consolidation of independent practices into hospital systems and make community care more sustainable. She recommended oversight—suggesting the Green Mountain Care Board receive data on rate setting and fairness among commercial payers—and highlighted technical concerns, such as how CMS fee schedules map to Vermont payment design for multiple CPT codes per visit.
Witnesses urged annual reporting on AHP enrollment, premiums and benefit design, disclosure requirements to help nonprofits choose plans, and a delayed effective date for AHP implementation to allow program development and assurance that protections are in place. Committee members asked insurers present to quantify projected savings and sought clarity about potential impacts on premiums and hospital finances.
The committee recessed for a break after hearing extensive testimony and indicated further deliberation on implementation details would continue.

