General reimbursement process of hospital individual services
Since 1997, Austria implemented gradually an activity-based hospital payment system called “Leistungsorientierte Krankenanstaltenfinanzierung (LKF)”. The aim of this diagnostic-related groups (DRG) system is – as in other countries – to increase transparency and efficiency of hospitals and accordingly to contain costs. The LKF system relies on two pillars: the core area (nationally uniform for all hospitals) and the steering area (with criteria to adapt to the level of hospital care and to Federal States) [22].
Similar to classic DRG systems, the relative costliness of individual cases [15, 22] is determined based on regular calculations using data from reference hospitals on costs of average cases. The diagnosis-related “cases” form groups (so-called “leistungsorientierte Diagnosefallgruppen”/LDF) which are either procedure-related or diagnosis-related. Based on LDF groups, point-value scores are calculated and determine the reimbursement to individual hospitals [15, 22].
The LKF model is annually updated by an interdisciplinary working group (hospital committee) coordinated by the MoH. In this process, new – most often costly – medical services can be introduced to the “individual services catalogue” – positive list of around 2,000 medical services – or price changes can be accounted for [15, 22]. Public hospitals can submit proposals on which medical services should be considered for inclusion into the hospital individual services catalogue (see figure 1).
There are key criteria for adoption of novel, or differentiation of already existing, medical services. A hospital individual service that is newly developed, technically established with a clear medical indication and with adequate scientific evidence, with certain economic relevance and a unit of service that is distinguishable from other services would, for instance, fulfil the criteria for inclusion into the hospital individual services catalogue. A deletion of a service may be considered, if, for instance, the service does not have sufficient evidence supporting its use or is no longer provided/ does not follow current medical standards [15]. The full list of all in- and exclusion criteria as well as criteria for deletion (disinvestment) can be found in table 2.
The focus group respondents described the hospital individual services catalogue as a rather broadly defined catalogue containing medical services that are eligible for financing. The respondents described the evolution of the individual services catalogue from capturing all services that are reimbursed in Austrian hospitals (note: with certain economic relevance), in the early years of implementing the DRG-system to additional aspects of relevance such as quality assurance and planning of services covered.
“(…) This means that a certain economic relevance is required to be considered/ not considered to be depicted in this catalogue. Small, less costly and less frequently utilised benefits can be coded with equivalent codes without being depicted in the catalogue as such. Capturing these benefits that are financed in Austrian hospitals was the initial idea of the hospital individual services catalogue. Later, other aspects such as quality assurance and planning were introduced as further relevant aspects of the catalogue. Hence, a more differentiated presentation began to evolve, without having a direct impact on financing due to the fact that the latter rates are still in the background (for which the more detailed services are summarised) (…)” (Focus group response 2020, 0:12:17).
Evidence-based reimbursement
Since 2008, interventions that are being considered for introduction into or deletion from the hospital individual services catalogue undergo evidence syntheses regarding the comparative effectiveness and safety. To prioritise relevant topics for these assessments, proposals by public hospitals and their regional hospital federations are listed and prioritized according to potential for true innovation, high cost and high volume of patient population, risk or uncertainty regarding value [15]. Evidence syntheses are conducted and recommendations based on GRADE [23] are formulated and provided to the MoH [14].
Informed by both published literature [16] and the focus group response, evidence-based recommendations and their impact on or implication for reimbursement decisions can be described as follows. Evidence-based recommendations in favour of the intervention (recommended) are usually formulated when there is strong evidence indicating a clinical benefit of the adoption of the intervention, and they support an adoption as a reimbursable hospital individual service without restrictions. If the clinical evidence is less robust, but still points in a beneficial direction, an adoption with restrictions is recommended. In those cases, decision makers will usually include the intervention as a fully reimbursable hospital individual service, but may couple it with certain restrictions (e.g., only in some hospitals with certain qualifications) and re-evaluate it at a later stage, potentially linked to the completion of registered, ongoing randomized clinical trials (RCTs). A preliminary rejection is usually recommended when there is no or inconclusive evidence, indicating a clinical benefit. In this scenario, the decision makers do not reimburse the intervention as such. However, it still may be included in the hospital individual services catalogue as a new examination and treatment method for the purpose of documentation (with a XN-Code). In 2021, overall eleven medical services are XN coded for documentation only. Then, the amount of eligible reimbursement is usually not changed; rather, hospitals usually get the minimum reimbursement based on LKF codes that were used prior to submitting the proposal. Update assessments are then conducted leading to either a) an inclusion as a reimbursable benefit, b) prolongation of the preliminary status, or c) the non-inclusion of medical service, i.e. its preliminary status will be deleted [15]. A recommendation to reject a certain intervention is formulated if there is strong evidence indicating no clinical benefit or if the harms exceed the benefits, leading to no inclusion in the hospital individual services catalogue. Table 3 gives a broad overview of evidence-based recommendation categories and the ideal type of responses to the recommendations.
Quantitative analysis of accordance between evidence-based recommendation and reimbursement decision
The quantitative comparison between evidence-based recommendation and subsequent decision for the annual maintenance of the hospital individual services catalogue in Austria shows a high rate of accordance. Between 2008 and 2020, 107 out of 118 (90.7%) evidence-based recommendations received an aligned decision (based on clinical evidence). There were only four negative recommendations (3.4%) for medical services which were then nevertheless adopted or not removed from the individual services catalogue. Further, there were seven positive evidence-based recommendations (5.9%) that resulted in a negative reimbursement decision. Table 4 gives a broad overview of the accordance between evidence-based recommendation and reimbursement decision. The whole list of all deviations (incl. product names) can be found in the online appendix 1.
It is to be noted that all deviations that occurred were not “strong” deviations. All of the “positive” recommendations that received a negative reimbursement decision were “reimburse with restriction” recommendations (as opposed to a strong recommendation for inclusion). Similarly, most of the deviations in the other direction (negative recommendation followed by a positive reimbursement decision) received a “preliminary” rejection and not a “full rejection”.
Aspects influencing reimbursement decisions
Based on the focus group and descriptive statistics/ contingency table of the accordance, we identified six types of aspects that may have played a role in the decision-making process for the annual maintenance of the hospital individual services catalogue. An overview of our findings can be found in table 5.
Comparative clinical effectiveness and safety (clinical evidence) notably constitute the major aspect in the decision-making process of reimbursement decisions of hospital medical services in Austria. This was evident both in the accordance between evidence-based recommendations and subsequent reimbursement decisions so far (see table 4) and during the focus group. The general principles of the annual maintenance of the hospital individual services catalogue were described as follows:
“(…) Or something comes along where you’d say: OHO, that's something scientifically new. We haven't had that yet, so that's a new variant for the therapy of (e.g.) hypotension by implanting something (…). Then, of course, it is interesting to look at the clinical benefit. And then there’s the question: Does it make sense or not? Then it's a matter of evaluating the evidence: Are there any studies at all, and if there are any, then you look at the benefit (…).” (Focus group response 2020, 0:21:58)
Quality assurance and organisational aspects: While distinct in the deductive category system, these aspects are not described separately due to significant overlap of the focus group. Notably, these are central aspects in the decision-making process to determine how medical services are included. This aspect evolved over time and the whole hospital individual services catalogue became, consequently, more detailed:
“Quality assurance is another aspect that has been added and that has led (…) to procedures (…) being mapped in a more granular way than they have been in the catalogue up to now, without the flat rates per case being split in the background (…).” (Focus group response 2020, 0:17:25)
Structural quality assurance plays a role in this context by setting conditions for the use of a medical service. If evidence is not that clear or other aspects hinder prompt decision making (such as situational aspects), the aspect of structural quality assurance was considered crucial before adopting a new treatment method into the standard financing system. The question arises which hospitals should be able to use a medical service so that it is assured that evidence-based services are delivered in hospitals only with the right qualifications and technical equipment. In one specific scenario of deviations the following was, among others, discussed:
“Well, the quality assurance/ I can only approve at the hospital level. That means: I need some criterion (...). The hospital is allowed to do it now because they somehow (...) have a heart catheter or no, they are not allowed to do it because they don't have heart surgery. So you have to/ that is still worth discussing.” (Focus group response 2020, 1:14:36)
With regard to minimum volume standards, it is mentioned that these do not play a role in the decision-making process but it is still useful to be able to document them.
The adoption may further be coupled to some hospitals for which certain local specialisations are already existent. The interviewer framed as to whether the discussants saw that local specialisations and the structural quality dimension also needs to be seen in the organisational context, which they agreed upon.
Costs: The aspect of whether a therapy is cost-effective does not appear to play a role in the decision-making process per se. However, if costs are comparable to already existing medical services, the new medical service may not be included in the catalogue separately.
“(…) It may also be that it turned out that the cost that was sent along for the LDL apheresis was the same as the plasmapheresis. There is also a basic service in the catalogue for selective cell adsorption. And then for both (…): Continue to code them under this mapped basic individual service.” (focus group response 2020, 0:55:07)
Procedural aspects: These aspects are linked to the general criteria for adoption of hospital individual services. That is, in certain contexts, a hospital individual service was not included as a reimbursable hospital individual service if, for instance, the proposals were incomplete (see exclusion criteria for medical services, above). Additionally, when annual maintenances were first initiated, there was no system in place to delete a hospital individual service. Some interventions were evaluated but could not be deleted. The system to delete a hospital individual service was established at a later stage.
Other countries: The focus group mentioned being influenced by how other countries (especially Germany) decided on the potential adoption of a certain medical service:
“(…) In Germany, as far as I know, it is also the case that it is not part of the standard funding. At least it wasn't in the spring of this year. They said they were waiting for another large study and when that was finished, 2021, then a decision would be made. So that's how it was written (…) at the back (note in the report).” (focus group response 2020, 1:11:01)
Situational aspects: The COVID-19 pandemic was identified as a situational aspect hindering the reimbursement of medical services. The COVID-19 pandemic hindered a physical meeting for two medical services that received a positive recommendation. In both of these cases, the re-imbursement decision was negative, although the medical services were included in the hospital individual services catalogue for the purpose of documentation. With respect to the question as to why the re-imbursement decision was not positive, the focus group responded that the cases
“(…) were completed during the first lockdown and are now both included as a NUB [note: new examination and treatment method] (…). Had we had a videoconference or a meeting at that time, we would have discussed/ do we decide for a service that requires authorization [=restricted reimbursement], and take it into the standard funding or do we leave it as a NUB. We would have done one of the two variants in any case. We have given ourselves the minimum variant here, so to speak, (…). I cannot say how this would have turned out if we had discussed it. It's possible that we would now have two more services requiring authorization.” (focus group response 2020, 1:08:38)
Reproducibility of reimbursement decisions
Focus group participants recalled a specific scenario, in which they believed that they may have been too strict in excluding a medical service, which should have been partly reimbursed followed by close monitoring and re-evaluation at a later stage. However, in this specific scenario the focus group did not remember the reasons behind the decision, as it had taken place over ten years earlier.