| Idee | Pilotprojekt | Strategiepapier | Gesetzgebung | Umsetzung | Evaluation | Veränderung/Richtungswechsel | ||
|---|---|---|---|---|---|---|---|---|
| Implemented in this survey? |
In January 2009, the existing risk structure compensation scheme between sickness funds has been expanded to include morbidity-oriented factors. The measure aims at preventing risk selection, improving care for patients with chronic diseases and equalizing starting points for competition between sickness funds. The introduction of morbidity-oriented risk structure compensation ("morbi-RSA") entails a major reorganization of financial flows which is highly controversial.
Reasons for risk structure compensation
The risk structure compensation scheme (Risikostrukturausgleich, RSA) between sickness funds was introduced in 1994 to strengthen solidarity in the health system and to create a framework for competition:
Shortcomings of the original RSA
The initial risk structure compensation scheme equalized differences in income-related contributions and differences in expenditure of sickness funds due to age, sex and invalidity. However, critics warned that
While the original RSA was later modified to include participation in a Disease Management Program (see below), it did not become truly morbidity-oriented.
The morbi-RSA: main objectives
Since January 2009, morbidity-based categories complement the previous compensation mechanism. The morbidity-oriented risk structure compensation scheme (morbiditätsorientierter Risikostrukturausgleich, morbi-RSA) is aimed at more equitable distribution of funds, corresponding to morbidity-related expenditure of sickness funds. Objectives are to
How the morbi-RSA works
The morbi-RSA balances differences in risk-related expenditure:

Additional payments to sickness funds for 80 defined diseases
sickness funds
| Innovationsgrad | traditionell |
|
innovativ |
| Kontroversität | unumstritten |
|
kontrovers |
| Strukturelle Wirkung | marginal |
|
fundamental |
| Medienpräsenz | sehr gering |
|
sehr hoch |
| Übertragbarkeit | sehr systemabhängig |
|
systemneutral |
Degree of innovation: The introduction of morbidity-based categories constitutes an ambitious reform of the previous risk structure compensation scheme which merely adjusted for age, sex and invalidity among insurees.
Degree of controversy: While the Government, the Federal Social Insurance Authority and sickness funds with many chronically ill patients support the morbi-RSA, other stakeholders and sickness funds are strongly opposed.
Impact: The morbi-RSA entails a major reorganization of the financial flows between sickness funds: almost half of the 168 billion Euro pooled in the health fund will be redistributed according to the new morbidity-based categories.
Public Visibility: While the topic is very prominent among sickness funds and health policy experts, the general public has not been extensively informed about the morbi-RSA by the stakeholders and by the media.
Transferability: Risk structure compensation schemes exist in several countries (e.g. in the Netherlands or Switzerland). While acknowledging international differences in health system organisation, other countries could learn from German experiences to a certain extent.
In January 2009, a financial reform of the social health insurance system, the final step of the Act to Strengthen Competition in Statutory Health Insurance passed in 2007,entered into force. The core elements are
The morbi-RSA entails a major reorganization of the financial flows between sickness funds: almost half of the 168 billion Euro pooled in the health fund will be redistributed according to the new morbidity-based categories. At the same time, the morbi-RSA is part of a wider health system reorganisation.
In addition (but regulated separately), remuneration of providers has become morbidity-oriented as well; by means of diagnosis-related groups (DRGs) for hospitals (since 2004) and standard service volumes for physicians in the ambulatory sector. Increased morbidity-orientation grounds on the idea of structuring financial flows according to medical criteria, in order to achieve a more patient-centred and a more efficient health system.
| Idee | Pilotprojekt | Strategiepapier | Gesetzgebung | Umsetzung | Evaluation | Veränderung/Richtungswechsel | ||
|---|---|---|---|---|---|---|---|---|
| Implemented in this survey? |
Since the introduction of risk structure compensation in 1994, the shortcomings of socio-demographic categories have been discussed. A scientific report, commissioned by the Federal Ministry of Health, concluded that unadjusted differences in morbidity levels would promote risk selection and hamper efforts of improving quality and efficiency in social health insurance (Jacobs et al, 2001). Other reports came to similar conclusions (e.g. Lauterbach & Wille, 2001).
Increasing evidence seemed to support morbidity-based risk structure compensation. At the same time, the range of data accessible to sickness funds expanded. In 1994, the choice of risk adjusters had been restricted by the availability of data: Age and sex became risk adjusters, as sickness funds could only collect socio-demographic data. Since 1999, however, sickness funds can access data on pharmaceutical prescriptions and inpatient diagnoses and, since 2004, data on outpatient diagnoses. The scientific community consented that direct morbidity-orientation in risk compensation was needed.
The Act to Reform the Risk Structure Compensation Scheme (RSA-Reform-Act)
To improve risk structure compensation based on scientific evidence, the German Bundestag (Federal Assembly, i.e. the lower house of the German Parliament) enacted a reform of the compensation mechanism. The Act to Reform the Risk Structure Compensation Scheme in SHI from 2001 aimed at
To achieve these aims, the RSA Reform Act stipulated two steps:
Looking beyond national borders
International experiences, particularly from the U.S. and from the Netherlands, guided the discussion on morbidity-oriented risk structure compensation. In the U.S., several morbidity-oriented classification models have been developed. In the Netherlands, first steps towards implementing morbidity-oriented risk compensation had been taken: Pharmaceutical cost groups introduced in 2002 and diagnosis cost groups introduced in 2004 served as an example for developing morbidity-based categories in the German context.
The approach of the idea is described as:
new: Guided by experiences from the U.S. and from the Netherlands, the introduction of morbidity-oriented criteria constitutes a new approach in the German risk structure compensation scheme.
amended: The existing risk structure compensation scheme, which was based on socio-demographic adjusters and invalidity among insurees, has been expanded to include morbidity-based categories.
The Federal Ministry of Health strongly supports the morbi-RSA and has made it a priority for the financial reform of the social health insurance system. The Ministry appointed a Scientific Advisory Board in 2007 to develop morbidity-based categories for risk structure compensation.
The Federal Social Insurance Authority is an independent authority in charge of implementing the risk structure compensation scheme. The Federal Social Insurance Authority is
empowered to take the final decision regarding the compensation rates.
A Scientific Advisory Board was entrusted with investigating appropriate diagnoses, weighting factors and classification models. Their report formed the basis for the decision of the
Federal Social Insurance Authority. While the Board stressed the importance of a morbi-RSA, the members stressed the importance of strictly applying the criteria stated by law. All Board
members resigned in March 2008 to express their discontent with, among others, the inclusion of diseases such as diabetes and hypertension in the morbi-RSAas such diseases were "preventable" and/ or
not "closely definable" and/ or not "highly cost-intensive" and, thus, did not conform to legal requirements (for definition of the terms, please see section "adoption and implementation").
Statutory Health Insurers are divided into supporters and opponents:
The Federal Association of Statutory Health Insurance Physicians claims that the morbi-RSA creates incentives for manipulation and corruption. The Association warns of alliances between payers and providers where providers are encouraged to "upcode" their patients so as to fit into the newly created morbidity categories.
| Regierung | |||
| Federal Ministry of Health | sehr unterstützend | stark dagegen | |
| Federal Social Insurance Authority | sehr unterstützend | stark dagegen | |
| Leistungserbringer | |||
| Federal Association of Statutory Health Insurance Physicians | sehr unterstützend | stark dagegen | |
| Kostenträger | |||
| Sickness funds with many elderly insurees/people with chronic conditions | sehr unterstützend | stark dagegen | |
| Sickness funds with many ?good risks? | sehr unterstützend | stark dagegen | |
| Wissenschaft | |||
| Scientific Advisory Board | sehr unterstützend | stark dagegen | |
The RSA-Reform-Act
In 2002, the Bundestag adopted the RSA-Reform-Act which stipulated two steps: the introduction of a "risk pool" and financial incentives for disease management programs as from 2002, and the inclusion of morbidity-based categoriesin RSA as from 2007 (see section "origins of health policy").
The Reform Deadlock
While the RSA-Reform-Act had scheduled 2007 for implementing the morbi-RSA, data collection problems and political obstacles resulted in a reform deadlock:
Morbi-RSA Gains Momentum Again
In their coalition agreement of 2005, Christian Democrats and Social Democrats agreed on refining and further improving the risk structure compensation scheme. This rather vague wording was specified during negotiations for the envisaged health care reform. The resulting political compromise yielded
The Legal Basis
The Act to Strengthen Competition in Statutory Health Insurance, passed in February 2007, and the subsequentamendments to the "risk structure compensation regulation" (Risikostrukturausgleichsverordnung, RSAV) created the main legal basis for introducing the morbi-RSA. The regulation governs
success
| Regierung | |||
| Federal Ministry of Health | sehr groß | kein | |
| Federal Social Insurance Authority | sehr groß | kein | |
| Leistungserbringer | |||
| Federal Association of Statutory Health Insurance Physicians | sehr groß | kein | |
| Kostenträger | |||
| Sickness funds with many elderly insurees/people with chronic conditions | sehr groß | kein | |
| Sickness funds with many ?good risks? | sehr groß | kein | |
| Wissenschaft | |||
| Scientific Advisory Board | sehr groß | kein | |
To implement the amended "risk structure compensation regulation", the following steps were taken:
"A learning system"
According to the Federal Social Insurance Authority, the morbi-RSA is a "learning system" which requires regular updating. So far, the morbi-RSA is limited to 80 diseases to prevent unforeseeable distortions in competition and to increase planning capacity of sickness funds. Though, the Federal Social Insurance Authority supports continuous improvement of the morbi-RSA by, for example, including age-morbidity interactions, to respond to the demographic and epidemiological transition. In that respect, the 80 diseases as well as the payments will be recalculated annually. A systematic evaluation of the morbid-RSA is, however, not yet planned or envisaged.
The introduction of morbidity-based categories in risk structure compensation has been highly debated. Expected trends and debated issues are outlined below.
A Year of Transition
As almost half of the 168 billion Euro pooled in the health fund will be redistributed according to morbidity-based categories, the morbi-RSA entails a major reorganization of financial flows. 2009 is supposed to be a year of transition where many sickness funds will struggle to survive. Experts expect several developments:
Stimulus for Innovative Care Management
The morbi-RSA challenges the traditional strategy of sicknes funds: attracting primarily healthy and wealthy insurees. For the first time, sickness funds can profit from sick insurees. This paradigmatic shift could considerably improve quality of care for patients with chronic conditions included in the morbi-RSA. Some sickness funds consider expanding
The rationale for this reorganization is twofold. Not only shall special offers attract patients with certain chronic diseases and, thus, entail additional premiums from the health fund. But an improved chronic care infrastructure is also increasingly seen as necessary for using the additional premiums efficiently.
More equity? - Yes, but only for some
The morbi-RSA was aimed at increasing equity at the level of sickness funds and at the level of insurees. At the level of sickness funds, morbidity-related distribution of funds is supposed to equalize starting points for competition between sickness funds. However, critics claim that
At the level of insurees, the degree of equity is debated as well:
… still Competition for Young and Healthy Insurees
Despite incentives to insure patients with certain diseases, many sickness funds still favour, in principle, young and healthy people for two main reasons:
Transparent Insurees?
As from 2009, sickness funds collect not only socio-demographic data, but also morbidity-related data on diagnoses and pharmaceutical prescriptions. Data security is debated. Sickness funds pseudonymise the data before sending them to the Federal Social Insurance Authority. However, sickness funds themselves are able to relate the data to their insurees. To receive additional allocations from the health fund, sickness funds need to match standing data and diagnosis-related data. Although matching is strictly limited to this purpose, there is a grey area. It is discussed, for example, whether sickness funds are allowed to match data to examine coding of diagnoses by physicians.
Incentives for Manipulation?
Many stakeholders criticize the possibility of manipulating diagnoses to receive additional premiums from the health fund. Minister of Health Ulla Schmidt denounces alliances between physicians and sickness funds, where physicians are paid for reviewing their diagnoses, as corruption. The debate focuses on the distinction between "up-coding" and "right-coding": All sickness funds officially disapprove of "up-coding" patients by assigning them a medically unjustified, but more lucrative diagnosis. Instead, the term "right-coding" is used for describing efforts to improve recording of existing, yet unreported morbidity.
Sending Costs Sky-High?
Critics warn that the morbi-RSA will increase costs for two main reasons. First, basing morbidity-oriented additional payments to sickness funds on diagnoses, partly "validated" through pharmaceutical prescriptions, is seen as a disincentive for cost-containment. Critics claim that, despite rising costs for pharmaceuticals and hospital treatment, insurers have an interest in promoting pharmaceutical prescriptions and inpatient diagnoses to receive additional allocations from the health fund. Second, critics caution that the morbi-RSA will increase reporting of cost-intensive diseases, as a result of either "right-coding" or "up-coding" (which, however, is easier in the ambulatory sector, where the first agreements between physicians and sickness funds have been signed to carefully document all diagnoses). The Federal Social Insurance Authority, though, stresses that the financial endowment of the health fund is fixed. Thus, proliferation of reported morbidity would merely reduce the monetary value of additional payments, to the detriment of sickness funds themselves.
Disincentives for prevention?
Critics claim that the morbi-RSA does not encourage investment in health, as strategies to prevent illness are not rewarded: there is the danger that sickness funds rather profit when they enlist many sick insurees. The Federal Social Insurance Authority presents two counterarguments to stress that sickness funds are still interested in prevention: First, if their clients are healthy, sickness funds will not receive additional allocations from the health fund. But they also avoid costs of disease. Second, according to the prospective procedure, diagnoses of the previous year determine how much money sickness funds receive in the subsequent year. Thus, sickness funds profit when their insurees´ health status improves over the years.
| Qualität | kaum Einfluss |
|
starker Einfluss |
| Gerechtigkeit | System weniger gerecht |
|
System gerechter |
| Kosteneffizienz | sehr gering |
|
sehr hoch |
Impact on quality of health care services: While the morbi-RSA may improve care for patients with chronic diseases (e.g. by expansion of case management programs), the overall impact on the quality of health care services cannot be assessed yet. In the long term, improved quality of care for patients with chronic might "spill over" to other patient groups or it will be to their detriment (if the focus remains on those with additional allocations).
Level of equity: The introduction of morbidity-oriented categories in risk structure compensation is aimed at more equitable distribution of funds, corresponding to morbidity-related expenditure of sickness funds. Particularly patients with chronic diseases which are included in the morbi-RSA may profit from innovative models of care. Regarding patients with the "wrong" diseases, though, the situation remains unchanged or worsens.
Impact on cost-efficiency: The morbi-RSA may easily influence behaviour of sickness funds and providers (through their contracts with the sickness funds). While this may be beneficial, i.e. that appropriate treatments will be given to a larger percentage of affected patients, "gaming" (i.e. treating patients who do not actually have a given disease as if they had it to label them accordingly). This would have a negative effect on both the quality and the cost-efficiency of the system. Only manipulating diagnoses ("up-coding") would also have a negative effect on cost-efficiency (while being neutral to quality). Overall, the hope is thoughthat sickness funds will be increasingly pressured to optimize allocation of resources by managing patients efficiently in the long term.
Bundesversicherungsamt. Festlegung der im morbiditätsorientierten Risikostrukturausgleich zu berücksichtigenden Krankheiten durch das Bundesversicherungsamt, 2008 (Available
online at www.der-gesundheitsfonds.de/fileadmin/redaktion/Dokumente/Risikostrukturausgleich/
20_Dokumentation_der_Festlegung.pdf)
Bundesversicherungsamt. So funktioniert der neue Risikostrukturausgleich im Gesundheitsfonds, 2008 (Available online at www.bundesversicherungsamt.de/cln_100/nn_1046668/DE/Risikostrukturausgleich/
Wie__funktioniert__Morbi__RSA,templateId=raw,property=publicationFile.pdf/
Wie_funktioniert_Morbi_RSA.pdf)
"Der Morbi-RSA bringt für Kassen den gläsernen Versicherten". Ärzte Zeitung, January 29, 2009. (Also available online at www.hautsache.de/News/Der-Morbi-RSA-bringt-fuer-Kassen-den-glaesernen-Versicherten.php)
"Fonds zwingt Kassen zum Umdenken". Financial Times Deutschland, February 13, 2009. (Also available online at www.ftd.de/unternehmen/gesundheitswirtschaft/:Gesundheitswirtschaft-Fonds-zwingt-Kassen-zum-Umdenken/473618.html?p=4)
Göpffarth, Dirk. Der Risikostrukturausgleich auf dem Weg zur direkten Morbiditätsorientierung. GGW (7) 3: 23-30, 2007
Jacobs, Klaus, Peter Reschke, Dieter Cassel and Jürgen Wasem. Zur Wirkung des Risikostrukturausgleichs in der gesetzlichen Krankenversicherung Eine Untersuchung im Auftrag des
Bundesministeriums für Gesundheit. Baden-Baden: Nomos, 2001. (Also available online at www.iges.de/publikationen/gutachten/rsa_gutachten/e5166/infoboxContent
5178/RSA-Gutachten2001_ger.pdf)
Jacobs Klaus und Sabine Schulze Der morbiditätsorientierte Risikostrukturausgleich: notwendige Funktionsbedingung für sinnvollen Wettbeweb in der GKV. GGW (7) 3: 7-14, 2007
Lauterbach Karl and Eberhard Wille. Modell eines fairen Wettbewerbs durch den Risikostrukturausgleich. Mannheim: Köln, 2001. (Also available online at www.medizin.uni-koeln.de/kai/igmg/endgutachten_rsa.pdf)
Reschke Peter et al. Klassifikationsmodelle für Versicherte im Risikostrukturausgleich. Bonn: Bundesministerium für Gesundheit und Soziale Sicherung, Referat Information Publikation, Redaktion, 2005
Schneider, Udo, Volker Ulrich and Eberhard Wille. Risk Adjustment Systems in Health Insurance Markets in the US, Germany, Netherlands and Switzerland. CESifo DICE REPORT Journal for institutional comparisons (6) 3: 37-49, 2008
Wasem, Jürgen. Die Weiterentwicklung des Risikostrukturausgleichs ab dem Jahr 2009. GGW (7) 3: 15-22, 2007
Figures 1 and 2: own translation of Bundesversicherungsamt. So funktioniert der neue Risikostrukturausgleich im Gesundheitsfonds, 2008: 5-6
Schang, Laura
Reviewer: Reinhard Busse, TU Berlin
This report was written during an internship at Bertelsmann Foundation. Laura Schang is studying the Bachelor of European Public Health in Maastricht.