Comment on AN37-Proposed Rule-Unknown Submitter

VA is both a health care provider as well as a payer for health care services. VA charges third party payers for the health care services it furnishes to certain veterans. VA bills third party payers for these services using its self-determined "reasonable charges," which are established annually based upon VA costs for furnishing such services. As a government entity, VA does not include a profit margin in its "reasonable charges" computations. In this proposed rule VA proposes to pay for the purchase of non-VA health care services at an amount that is less than its own determined cost of providing such service within its own faciliites, as compared by the Medicare reimbursement rate versus VA "reasonable charges" for the service. What is the reason VA will not use its own determined "reasonable charges" as the amount payable for the purchase of similar non-VA health care? VA collects more from third party payers for billed health care services than it pays non-VA health care providers for the same services using the corresponding Medicare reimbursement amount. If VA adopts Medicare reimbursement rates for the payment of purchased non-VA care and such rates are less than VAs own determined cost of furnishing the services itself, then VA should close its doors and purchase all health care services for veterans in the private sector, as it is less expensive than providing the services within VA facilities. Without regard to such hypocrisy, VA should base its payment rates for the purchase of non-VA health care on its own "reasonable" costs for providing such services internally.