Where should I start? Health sharing succeeds only on the basis of trust of its members. Trust can only exist with transparency. Blind faith isn’t enough, and Liberty hasn’t been transparent enough.
Identifying Recent Failures
Mismanagement, and sometimes other failures, sometimes happen. You can’t undo them. Lost, mishandled, or delayed processing–it happened. It can’t un-happen, but it can be made right by those affected.
What shouldn’t have happened, and is inexcusable, is the breakdown in communication when things weren’t running smoothly.
When things aren’t running smoothly, don’t stop reporting sharing statistics. Members need to know that the pool is solvent and that it’s likely able to pay their unexpected medical need in the future. If the books were a mess, and you didn’t really know how many bills had been submitted, say so. If you don’t know in July how you did in June, get it figured out and report it in August.
There may have been some recognition of this problem when September’s newsletter included year-to-date monthly stats. But there wasn’t any reporting from October 2018 to March 2019, and another lapse between March and August. I requested those numbers directly a long time ago, with no response. See the blank entries on the chart here.
Financial figures need to be included directly in e-mail messages, as was done prior to mid-2018, so that members that keep the e-mails have the information contained in them. Switching to graphical representations, incorporated in HTML, makes the images worthless from an archival standpoint. If you insist on graphical images, at least properly populate the alt-text fields for users with disabilities and so that the information exists when you delete the images from your servers.
Publish an annual report, each year summarizing Liberty’s membership and finances, as was published in 2018 for 2017. (See here or here.) All annual reports should reside in one place on Liberty’s website, instead of in traces of files left behind as older links have been broken and files removed.
We’re long overdue for a report reviewing what happened in 2018, and should be able to expect one soon for 2019.
But the reports also need to show more, especially when members are asked to vote on various changes to the sharing guidelines. Liberty’s membership includes enough people that data about the expenses shared can be published without any undue privacy implications. For any given year, we should know how much of the sharing falls into the following categories, maybe more:
- Routine care (physical exams, vaccines, colonoscopies, etc.)
- Maternity care
- Pre-existing conditions (broken down by those identified during the application process, and those identified through reviews of claims)
- Accidents vs. illnesses (i.e. separating the fall that breaks a bone from the stomach bug or heart attack)
Include member demographics in reporting how many individuals and families there are, and break out expenses by type of membership. Members need to have confidence that share amounts align with expenses incurred by each group. What’s the age distribution in each group? How many members have health coaches in each group? What are the graduation statistics from that program (compared to those that participate for a year and continue as members without meeting health targets)?
How many bills are being processed? Are there certain member groups or types of incidents that result in a disproportionate number of bills relative to the expense amounts?
We should also see a histogram showing the number of members with expenses in a series of dollar ranges for the year. How many members had expenses less than the AUA? How many exceeded $10,000? $100,000? What’s the distribution of incidents as a function of cost and duration?
Of course, all of these statistics should already exist to inform Liberty’s board and the decision-making processes that are ongoing.
This one should be easy. Each year, when Liberty files its form 990 with the IRS, it checks the box that its financials for that tax year have been audited by an independent accountant. It also declares that it “has a committee that is responsible under its governing documents or through delegation by its governing body for (i) overseeing the compilation, review, or audit of the financial statements, and (ii) the selection of an independent accountant that compiled, reviewed, or audited the statements.” The 2017 audit is available online here, the rest need to be as well.
If you’ve looked–even briefly–at the organizational structure and how things operate, you know how hard it is to follow. You likely expect inefficiencies, mistakes, and unnecessary costs. Why the complexity?
- Gospel Light Mennonite Church Medical Aid Plan, Inc.
- National Coalition of Health Care Sharing Ministries, Inc.
- Cost Sharing Solutions, LLC
- Health Share Pro, LLC
- Peachtree Wellness Cooperative, LLC
- Bow Tie Medical Ohio, LLC
- The Medical Cost Savings Solution, Ltd.
- Medcost Solutions, LLC
- Cavalry Health Sharing Ministry
- Liberty Healthshare Council, Inc.
- …and others.
Many of these organizations are either the constructs of board members or family members of board members, and many of them are for-profit corporations. Since Liberty is spending a large share of its administrative fees (over $64 million in 2017) with a company led by a close family member, we need more information about the structure of the agreements between them, and perhaps more independent oversight. If Liberty isn’t processing bills, it needs to be clear who is. If Liberty isn’t dealing with providers and tackling pricing activities in house, it needs to be clear who is. When the marketing budget is as large as it is, we should understand the relationships with those firms, and what results from those expenditures. I’ll discuss some of these arrangements–to the extent I’ve been able to piece together the relationships–in my next post.
In the context of sharing medical expenses, we obviously volunteer some sensitive information. We share information about our health with Liberty, and our providers often do the same. When Liberty shares that information externally, to organizations that we may not have any direct relationship, members need to know. California recently passed legislation requiring certain disclosures when collecting personal information, including the purpose of the data collection and who might have access outside the organization.
Members need to know who has their information, which includes credit card and/or checking account details, health history, and familial relationships. Much of the information needed for identity theft exists in records Liberty maintains and shares. The generic boilerplate policy that currently exists doesn’t give the member (or potential member) the expectation that ALL of their information passes through for-profit entities, and doesn’t indicate what obligations those entities have for securing the data.
Of course, if we understood the list of interconnected organizations better, those privacy concerns might diminish.
Transparency Going Forward
Once we address the historical failures, and clarify what happened over the last 24 months or so, we need to make sure the organization is healthy going forward.
We need to understand–more than just a superficial leadership change–the organizational, administrative, and communication systems and controls implemented. We need to see the conflict-of-interest policies and org charts. Members need to understand the chain-of-command when issues arise, and what should be in place to make sure expenses process and share in a timely manner.