The United States spends more on healthcare than any country in the world—yet Americans are not demonstrably healthier for it. For decades, policymakers have tried to control costs by adding oversight: more reporting requirements, more utilization reviews, more payment controls, and more regulatory guardrails.
But what if the problem is not too little oversight—but too much system complexity?
Over time, the U.S. healthcare system has evolved into a financing system wrapped around a care delivery system—rather than the other way around. As healthcare financing has grown more intricate, so has the administrative machinery required to operate it. A significant share of spending now goes not to care itself, but to managing the processes surrounding it.
A simpler model—one that relies more on direct payment between patients and providers—could remove much of this administrative infrastructure and redirect resources back toward care.
The Administrative Cost Problem
Healthcare is one of the few industries where the administrative apparatus rivals the service itself in scale. Estimates suggest that administrative activities—billing, coding, claims management, prior authorization, contracting, and compliance—account for roughly 15–30 percent of total U.S. healthcare spending.
These costs arise largely from the fragmented nature of the American healthcare financing system. Providers must navigate multiple insurers, benefit structures, coding rules, and authorization processes. A single clinical encounter can trigger a chain of administrative steps involving eligibility verification, documentation requirements, claims submission, adjudication, and appeals.
Much of this infrastructure exists to control costs or prevent misuse. Yet paradoxically, the administrative complexity itself has become a major driver of spending. Analysts estimate that a substantial portion of healthcare administrative costs produce little measurable benefit for patient outcomes, representing hundreds of billions of dollars annually.
In many other industries, direct payment models simplify transactions by reducing the number of intermediaries involved. A cash-based healthcare model could have a similar effect.
Oversight Has Not Eliminated Fraud
One of the main justifications for healthcare’s administrative layers is fraud prevention. Programs such as prior authorization, clinical review, and payment integrity audits are intended to ensure that only appropriate services are reimbursed.
Yet fraud and improper payments remain persistent challenges across both public and private healthcare programs. The Government Accountability Office continues to designate federal healthcare programs as high-risk for improper payments, citing the scale and complexity of the system as a key driver of vulnerability (GAO-25-107753).
Fraud schemes evolve rapidly, adapting to new billing codes, reimbursement models, and technological platforms. In a system involving trillions of dollars, thousands of payers, and millions of daily transactions, opportunities for exploitation inevitably emerge.
If ever-increasing layers of administrative oversight have not eliminated fraud, policymakers must ask whether those layers are delivering value commensurate with their cost.
A simpler system—one built on transparent prices and direct payment—would not eliminate fraud entirely. But it could reduce the administrative surface area where manipulation occurs.
When Cost Controls Create New Incentives
Healthcare policy often relies on regulatory guardrails intended to protect consumers. One of the most prominent examples is the Affordable Care Act’s Medical Loss Ratio (MLR) rule, which requires insurers to spend at least 80–85 percent of premium revenue on medical care and quality improvement rather than administrative costs or profit.
The policy was designed to ensure that insurers devote most premium dollars to patient care.
But economic incentives rarely remain static. Analysts have noted that some insurers have adapted to the rule in ways that comply with its letter while undermining its intent. Research highlighted by the Foundation for Research on Equal Opportunity suggests that vertically integrated insurers—those that own physician groups, pharmacies, or other healthcare services—can shift revenue internally. Payments to affiliated providers count as “medical spending” under MLR rules, even though the funds remain within the same corporate structure.
In effect, higher spending can help insurers satisfy regulatory requirements. A policy designed to restrain costs may inadvertently reward them.
This dynamic illustrates a broader challenge of healthcare regulation: the more complex the rules become, the more opportunities exist to optimize around them.
Spending More, Achieving Less
Ultimately, the success of any healthcare system must be judged by its outcomes. By that measure, the U.S. system faces a difficult contradiction.
Americans spend far more per person on healthcare than residents of other high-income countries, yet the United States often ranks worse on key health indicators such as life expectancy and chronic disease outcomes. International comparisons compiled by the Peterson-KFF Health System Tracker highlight the persistent gap between spending and results.
The explanation cannot be found solely in clinical practice. Structural inefficiencies—including administrative overhead, fragmented financing, and misaligned incentives—play a significant role.
If even a fraction of the administrative spending embedded in the current system could be reduced, the financial impact would be enormous.
The Case for Simplicity
A cash-based healthcare model would not eliminate insurance. In fact, insurance would become more important—but in a more focused role.
Historically, insurance existed to protect individuals against rare but financially devastating events—serious illness, trauma, or major hospitalization. Over time, insurance expanded to cover routine services, pulling everyday care into a complex reimbursement system that drives administrative overhead throughout the healthcare economy.
A simplified system would return insurance to its original purpose: catastrophic coverage for major medical events such as accidents, cancer treatment, or serious disease.
Routine care—primary care visits, diagnostics, and many common procedures—could increasingly operate through transparent, direct payment between patients and providers. Prices would be known in advance. Providers would spend less time navigating billing codes and authorization requirements. Patients would have clearer visibility into the cost of care.
Most importantly, the system could function with far fewer administrative intermediaries.
The United States does not lack medical innovation. It leads the world in research, biotechnology, and clinical breakthroughs. What it often lacks is structural simplicity.
For policymakers and business leaders seeking to control healthcare costs, the lesson may be counterintuitive. The path forward may not lie in adding new layers of regulation, oversight, and compliance. It may lie in removing some of them.
A healthcare system that relies more heavily on direct transactions—while reserving insurance for catastrophic risk—could redirect billions of dollars away from administrative processes and back toward care.
In a system as complex as American healthcare, simplicity may be the most disruptive reform of all—and one of the few that could lower costs without compromising care.
Sources
Administrative Costs in U.S. Healthcare
- Health Affairs – “The Role of Administrative Waste in Excess U.S. Health Spending”
https://www.healthaffairs.org/content/briefs/role-administrative-waste-excess-us-health-spending
Research estimates that administrative activities account for roughly 15–30% of U.S. healthcare spending, reflecting billing complexity, insurance administration, and regulatory compliance. - JAMA – “Administrative Expenses in the U.S. Health Care System”
https://jamanetwork.com/journals/jama/fullarticle/2785479
Peer-reviewed analysis estimating that administrative costs represent 15–25% of total national health expenditures, amounting to hundreds of billions annually.
Improper Payments and Fraud Risk
- U.S. Government Accountability Office – “Improper Payments: Information on Agencies’ Fiscal Year 2024 Estimates” (GAO-25-107753)
https://www.gao.gov/products/gao-25-107753
GAO reports $162 billion in improper federal payments in FY2024, with healthcare programs such as Medicare and Medicaid accounting for a large share. - GAO WatchBlog – Federal Improper Payments Analysis
https://www.gao.gov/blog/federal-government-made-estimated-162-billion-improper-payments-last-fiscal-year
Provides additional explanation of improper payment risks across federal programs and long-term trends in fraud and payment errors.
Medical Loss Ratio and Policy Incentives
- Foundation for Research on Equal Opportunity (FREOPP)
“Gaming the Medical Loss Ratio: How Health Insurers Turn Consumer Protections Into Corporate Windfalls”
https://freopp.org/oppblog/gaming-the-medical-loss-ratio-how-health-insurers-turn-consumer-protections-into-corporate-windfalls/
Analysis of how vertical integration between insurers and providers can allow spending to count as “medical care” under ACA Medical Loss Ratio rules, potentially weakening the policy’s cost-control intent.
International Spending and Outcomes
- Peterson-KFF Health System Tracker – International Comparisons of Healthcare Quality and Spending
https://www.healthsystemtracker.org/chart-collection/quality-u-s-healthcare-system-compare-countries/
Data comparing the United States with other high-income countries, showing higher per-capita healthcare spending but mixed or lower performance on several health outcomes.
- Commonwealth Fund – “High U.S. Health Care Spending: Where Is It All Going?”
https://www.commonwealthfund.org/publications/issue-briefs/2023/oct/high-us-health-care-spending-where-is-it-all-going
Analysis of drivers of excess U.S. healthcare spending, including administrative complexity as a major contributor to higher costs relative to peer nations.

Joanne M. Frederick
Joanne M. Frederick, CEO of Government Market Strategies.






