Official Policy Framework

Restoring the Buyer

A Comprehensive Policy Framework for Consumer-Anchored Healthcare Reform

January 2026 • Healthcare Redesign

Executive Summary

U.S. healthcare is exceptionally expensive not because of higher quality but due to market design: patients are insulated from prices by insurers, which cripples competition and accountability. Nearly 18% of GDP goes to health care, yet large inefficiencies persist. For example, a recent analysis found U.S. hospital administrative expenses ($687B in 2023) are roughly double what hospitals spend on direct patient care, while international comparison shows the U.S. spends five times more per capita on administration than other wealthy nations.

Hidden, negotiated pricing causes extreme variation—e.g., the same coronary bypass surgery has been negotiated for as little as ~$28K or as much as $248K in the same region. Vertical integration (hospitals buying physician practices) has also sharply raised prices (15% higher for physicians' services post-merger) with no evidence of better quality.

Key takeaways: Independent research (RAND, MedPAC, CBO, Bipartisan Policy Center) warns that these distortions waste hundreds of billions. By contrast, consumer-driven approaches that restore "skin in the game"—funded health accounts, high-deductible insurance, transparent prices, and competitive primary care—can lower costs and improve value.

I. Introduction: The Economic Void at the Heart of American Healthcare

The United States healthcare system operates in a state of profound economic dissonance. It is a sector defined by advanced technological capability and clinical excellence, yet it is simultaneously crippled by a pricing mechanism that defies the fundamental laws of supply and demand.

The central thesis of this report validates the premise that the root cause of this dysfunction is not merely the volume of funds flowing into the system, but the structural "insulation" of the consumer from the economic transaction. This separation—whereby the patient consumes care but a third party adjudicates payment—has created a "Buyer's Void."

II. The Structural Pathology of the Third-Party Payer System

To understand the necessity of a consumer-anchored model, one must first diagnose the specific economic pathologies engendered by third-party payer dominance. The current system is not a market in the traditional sense; it is a complex bureaucratic apparatus where revenue is derived from maximizing reimbursement codes rather than maximizing value for the patient.

The Administrative Wedge: The High Cost of Intermediation

A defining characteristic of the U.S. healthcare system is the immense volume of resources diverted from clinical care to administrative processing. Data from 2025 reveals that administrative costs now account for roughly 66.5% of hospital spending, compared to just 33.5% for direct patient care [3].

Research indicates that U.S. healthcare administrative spending totals approximately $1 trillion annually. The friction of processing a single claim can range from $12 to $19, acting as a tax on the system that erodes the purchasing power of premiums and tax dollars.

The Distortion of Price Formation

In the U.S. healthcare market, prices are administratively constructed or negotiated in secret. This opacity creates an environment where extreme price variation is the norm.

  • The negotiated rate for a coronary bypass can range from $27,683 to $247,902 within the same geographic region.
  • HCCI site-neutral analyses, including transthoracic echocardiography categories, show materially higher allowed amounts in hospital outpatient settings than physician-office settings [2].

These disparities are fueled by "site-of-service" payment differentials where Medicare and insurers reimburse hospital outpatient departments significantly higher rates than independent physician offices for identical services.

The Consolidation Crisis

Between 2012 and 2024, the percentage of physicians employed by hospital systems rose from under 30% to at least 47% [9]. Empirical research demonstrates that when hospitals acquire physician practices, prices for services rise by an average of 14.1% with no measurable improvement in quality [10].

III. The Failed Experiment? Re-evaluating High Deductibles

The "first-generation" consumer model (HDHPs) failed to account for the complexity of medical decision-making. Faced with the full cost of care, many patients simply avoided care altogether, a phenomenon known as "behavioral hazard."

The "Next-Generation" model should avoid broad "high-value service" exemption categories, which can expand over time and recreate first-dollar spending. Instead, first-dollar coverage should be narrow and explicit: annual preventive physicals only, with clear incentives (or penalties, unless medically waived) to ensure completion. Nearly all other routine spending should flow through HSAs to preserve price discipline and patient purchasing power.

This explicitly addresses the most common counterargument: if broad "high-value" carve-outs are allowed, the system will pressure policymakers to label more services as exempt, expanding first-dollar coverage and eroding consumer discipline. A single annual-physical standard is transparent, auditable, and resistant to category creep.

IV. The "Funded" Consumer: Transforming Subsidies into Assets

For a consumer market to function, the consumer must have capital. We propose the "HSA Option" [27], which allows low-income exchange enrollees to receive their subsidy as a direct deposit into an HSA rather than a premium credit. This transforms the subsidy from a passive benefit into an active asset.

For the employer market, the Individual Coverage Health Reimbursement Arrangement (ICHRA) allows employers to contribute tax-free dollars that employees use to buy portable, individual coverage. By 2025, ICHRA adoption among large employers grew by 34% [29].

V. Restoring the Market: Direct Primary Care (DPC)

If the HSA provides the capital, DPC provides the venue. By eliminating the insurance intermediary, DPC practices reduce overhead by 40-60% [32].

Case Study: Union County, NC

Facing rising costs, Union County offered a DPC option. In the first year, they saved over $1.28 million, with DPC participants incurring 23% lower medical expenses than peers in traditional plans [34].

VI. Disciplining the System: Reference-Based Pricing (RBP)

For surgeries and complex care, RBP sets a maximum reimbursement limit pegged to Medicare rates (e.g., 140% of Medicare). The State of Montana saved approximately $47.8 million by implementing this model, forcing hospitals to compete against a transparent standard [40].

Table 1: Impact of Market Interventions (2024-2025 Data)

Intervention Key Mechanism Observed Outcome Source
Hospital Consolidation Acquisition of independent practices Prices rise ~14.1%; No quality gain [10]
Reference-Based Pricing Capping reimbursement at % of Medicare 19% market share shift; ~$48M savings [40]
Direct Primary Care Flat monthly fee; no insurance billing 40-60% overhead reduction [32]
HSA Option (Proposed) Converting subsidies to HSA deposits Projected $1,500 benefit for low-income enrollees [27]

VII. The Dynamic Safety Net: Engineering Automatic Replenishment

A purely consumer-driven system faces a critical vulnerability: the "running out of money" problem. To address this, we propose a mechanism of "Automatic Replenishment" inspired by supply chain logic.

In this model, if a low-income patient's HSA balance falls below a critical threshold due to medically necessary spending, a subsidy trigger refills the account [44]. This creates a "Reverse Deductible"—ensuring liquidity for the sickest patients while maintaining market discipline for the healthy.

VIII. Economic Impact Analysis: Labor Markets and Deficits

The Yale study on hospital pricing provides a critical data point: a 1% increase in healthcare prices lowers payroll at non-health firms by 0.4% [11]. Conversely, restraining price growth acts as a stimulus for wages.

Table 2: Price Variance by Site of Service (2025 Data)

Service Hospital Outpatient Cost Independent Cost Differential
Transthoracic Echocardiography (Category) Higher allowed amounts in HOPD settings Lower allowed amounts in office settings Material differential
Chest X-Ray ~$66 (Medicare Rate) ~$17 (Medicare Rate) ~4x
Colonoscopy $2,454 (Median) ~$800 (ASC Estimate) ~3x
Knee MRI ~$900 ~$600 ~1.5x

Source: HCCI site-neutral services analysis [2]

IX. Implementation Roadmap and Conclusion

1. Enact the "HSA Option"

Congress should transform ACA CSR subsidies into refundable tax credits deposited into HSAs for low-income exchange enrollees.

2. Mandate Site-Neutral Payment

CMS should finalize and expand site-neutral rules. All payors must reimburse outpatient services at the same rate regardless of setting [8].

3. Promote HSAs and ICHRAs

Encourage employers to adopt HSA-eligible plans and Individual Coverage HRAs.

4. Transparency and Reference Pricing

Federal and state regulators should require public reporting of negotiated prices. States could pilot reference pricing for state employees.

5. Strengthen Safety Nets

Use Section 1332 waivers to create "auto-funding" mechanisms for sicker patients.

Conclusion

The United States does not have a healthcare funding problem; it has a market design problem.

"Restoring the Buyer" is not an ideological abstraction but a pragmatic economic necessity. By anchoring the system in the consumer—armed with capital (HSAs), information (Transparency), and fair market rules (Site Neutrality)—we can reverse the consolidation trends, strip out administrative waste, and align the financial health of the system with the physical health of the patient.


Works Cited

1. Trilliant Health, 2022 Annual Report. Link

2. Health Care Cost Institute: Trends in Utilization and Prices for Site-Neutral Services in Hospital Outpatient and Physician Office Settings. Link

3. Trilliant Health: Hospital Administrative Expenditures Exceed Direct Patient Care by Nearly 2x. Link

4. PubMed Central: Active steps to reduce administrative spending associated with financial transactions in US health care. Link

5. California Health Care Foundation: Administrative Waste. Link

6. HLTH: New Trilliant Health Report Exposes Widespread Price Variation in U.S. Healthcare. Link

7. Health Care Cost Institute: Prices in Hospital Outpatient Departments are Consistently Higher than Physician Offices. Link

8. Bipartisan Policy Center: Site Neutrality in Medicare Payment. Link

9. U.S. GAO: Health Care Consolidation. Link

10. Yale News: Hospital takeovers of physician practices drive up health care prices. Link

11. Tobin Center: Who Pays for Rising Health Care Prices? Link

12. KFF: 2025 Employer Health Benefits Survey. Link

13. PMC-NIH: Consumer-Directed Health Care. Link

14. MotivHealth: The Upside of HSAs, HDHPs and ICHRAs. Link

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17. KFF: Americans' Challenges with Health Care Costs. Link

18. PMC: Health Care Affordability Problems by Income Level. Link

19. AJMC: Trends in Hospital Pricing for Vulnerable Emergency Department Users. Link

20. Trilliant Health: Report Reveals Unexplainable Differences in Actual Healthcare Prices. Link

21. Turquoise Health: Is Price Transparency Helping. Link

22. Georgetown CHIR: Unpacking Price Transparency Provisions. Link

23. Diabetes Care: Can Preventive Drug Lists Make High-Deductible Health Plans Safer? Link

24. ResearchGate: Reduced Cost-sharing for Preventive Drugs. Link

25. KFF: Expansions to Health Savings Accounts. Link

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27. Paragon Health Institute: The HSA Option. Link

28. Softheon: 4 ICHRA Trends. Link

29. Remodel Health: Growth trends for ICHRA. Link

30. Hint Health: Employer Trends in Direct Primary Care 2025. Link

31. HRExecutive: Plan on Personal - How ICHRA Empowers Employees. Link

32. Carolina Journal: Union County's DPC option. Link

33. Phillips Lytle: Direct Primary Care Model. Link

34. John Locke Foundation: Direct Primary Care for Local Governments. Link

35. Sana Benefits: Rosen Hotels' onsite primary care model. Link

36. Nebraska Legislature: Strada healthcare Direct Primary Care Pilot. Link

37. aequum LLC: Reshaping Employer Health Care With Reference-Based Pricing. Link

38. CRFB: Reference Pricing for the FEHB. Link

39. VSEA: Reference Based Pricing. Link

40. Healthcare Value Hub: MONTANA Snapshot. Link

41. PMC-NIH: Impact of Reference Pricing. Link

42. LKY School: The healthcare system in Singapore. Link

43. AIC: Medifund. Link

44. EBRI: Reference Pricing for Health Care Services. Link

45. University of Toledo: 340B Program Policy. Link

46. Medline: Maintaining accurate par levels. Link

47. Mass.gov: Response to DON questions. Link

48. KFF: The New ACA Repeal and Replace. Link