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					                            Commonwealth of Massachusetts
                          Health Care Quality and Cost Council
                              Two Boylston Street, 5th floor
                                   Boston, MA 02116

 DEVAL L. PATRICK           617-988-3360 • Fax 617-727-7662 • TTY 617-988-3175             JUDYANN BIGBY, M.D.
     Governor                           www.mass.gov/healthcare                                  Chair
TIMOTHY P. MURRAY                                                                          KATHARINE LONDON
Lieutenant Governor                                                                         Executive Director


   August 20, 2008


   Dear Hospital Chief Financial Officer and Quality Staff:

   As you know, Massachusetts law requires the Massachusetts Health Care Quality and Cost Council
   (“Council”) to post health care quality and cost information on a consumer-friendly website. The
   website is intended “to assist consumers in making informed decisions regarding their medical care
   and informed choices among health care providers.” (M.G.L. c. 6A, § 16K(e), as amended by Chapter
   305 of the Acts of 2008). The Council believes that the website will also help to inform a public
   conversation about health care costs and opportunities for controlling costs going forward.

   The Council is providing data for display on the website for your review. The data will be made
   available to you through INET, a secure internet-based data exchange facility operated by the
   Massachusetts Division of Health Care Finance and Policy (“Division”). If you need information on
   how to access INET, please contact the Division’s Help Desk at 800-609-7232 or by email at
   dhcfphelpdesk@state.ma.us.

   The Council is providing this confidential data for your review as authorized by regulation 129 CMR
   4.00: Disclosure of Health Care Claims Data to a Provider. 129 CMR 4.03, entitled Data Disclosure
   Procedures, states the following:

           (1) The Council may disclose to a Provider some or all of a [Health Insurance] Carrier’s Health
               Care Claims Data that the Carrier received from that particular provider and submitted to
               the Council pursuant to M.G.L. c. 6A, § 16L(d) and 129 CMR 2.00. The Provider may
               submit, in writing and within a time period specified by the Council, comments to the
               Council regarding the Health Care Claims Data. The Council shall consider any such timely
               submitted comments prior to publication of data on the Council’s website.

           (2) The Provider shall maintain the confidentiality of the Health Care Claims Data it receives
               from the Council. The provider shall not disclose the Health Care Claims Data except to the
               Council or as otherwise provided by applicable state or federal law.

   Note that Chapter 305 of the Acts of 2008 recently amended M.G.L. c. 6A. The Council’s authority for
   this disclosure is now at M.G.L. c. 6A, § 16K(e).
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Hospitals may submit one comment of up to 400 words for display on the Council’s website. This
comment will be displayed together with the hospital’s quality and cost information, the hospital’s
contact information, and a link to the hospital’s website. In this comment field, hospitals may wish to
describe the hospital, the types of services it provides, and special awards or recognition received.
Submissions that exceed the 400 word limit will be cut to 400 words.

In addition to the general comment for display on the website, the Council is asking hospitals to review
individual data elements for display, and if desired, to submit detailed responses regarding these
individual data elements. Council staff and consultants will review these detailed responses, but they
will not be displayed on the website. Note that data submitted to Council in response to this letter shall
not be deemed a public record and shall be kept confidential by the Council, pursuant to M.G.L. c. 6A,
§16K(f), as amended by Chapter 305 of the Acts of 2008, and regulation 129 CMR 4.00. Council staff
will review each timely submitted response prior to publication of data on the website. The Council
may exclude data from publication based on the hospital’s detailed response.

The Council is looking for each hospital to confirm that the cost measures the Council calculated from
its health care claims dataset are reasonably representative of the hospitals’ total commercial
population for each service. Given the wide range in payment levels, the Council has defined
“reasonably representative” as cost measures that differ from cost measures for the total commercially
insured population by less than 10%.

Hospitals may also wish to note any errors the Council may have made in importing quality measures
correctly from publicly available datasets and from the Division’s hospital discharge dataset.

The Council requests a response to the following questions for each of the data elements for display on
the website.

       a. Median Cost: For each service, does the median payment for the service (including both
          plan paid amount and patient amount due) reported by the Council differ from the hospital’s
          median payment amount for the service for all commercially insured patients by more than
          10%?

           Would the hospital’s median payment for all commercially insured patients be rated in a
           different cost rating category ($, $$, $$$, $$$$) than the median payment reported by the
           Council? Note that the Council assigns outpatient cost ratings based on where the hospital’s
           own median (50th percentile) payment falls relative to the statewide distribution (15th
           percentile, 50th percentile, 85th percentile) of all hospital medians; these figures are
           included in the hospital’s summary Data Verification Report. Because the Council assigns
           inpatient cost ratings based on severity adjusted medians, hospitals may not be able to
           analyze this question with respect to inpatient services.

           Please provide a detailed explanation for any significant disparity. For example, is there an
           issue with a particular payer’s data? Is there an issue with the diagnosis codes or DRG
           grouping? Is there a significant difference between the claims data collected by the Council
           and claims data for the hospital’s total commercially insured population? What proportion
           of claims is affected by this issue?
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       b. Global Fees: For each service, does the amount paid by the plan include fees (for example,
          professional fees, or fees for services provided before or after the date(s) of service) in
          addition to the facility fee for the service? Does the hospital receive a separate lump-sum
          payment for these services, in addition to the claims payment amount? What proportion of
          claims is affected by this issue? Do these additional fees comprise more than 10% of the
          median payment amount reported by the Council? If so, please report the hospital’s median
          payment amount per visit or per discharge for these additional fees for this service for all
          private pay patients.

Please email your response and any questions or comments to hcqcc@state.ma.us by September 17,
2008. Your response should include:

       Data Review:
             1. Attached Response Form
             2. Claims Data back-up - see format in Response Form
             3. Narrative explanation in MS-Word document

       General Comments for Display on website:
       Send comments in MS-Word document. 400 word limit.

The following documents can be accessed from the home page of the Division’s website at
www.mass.gov/dhcfp.

      Council’s letter to the hospitals
      Inpatient Information: MS-Excel spreadsheet (note multiple tabs)
      Outpatient Information: MS-Excel spreadsheet (note multiple tabs)
      Response Forms: MS-Excel spreadsheet (note multiple tabs)
      Explanation of Severity Adjustment from 3M (Computing Expected Value and Risk Adjusted
       Value for Charges): PDF file format

The Massachusetts Hospital Association (MHA) has scheduled conference calls on August 21, 2008,
2:30 p.m. and September 5, 2008, 10:00 a.m. for my staff and me to answer your questions regarding
this data review process. For more information about these calls, please contact Leanne Banks
(lbanks@mhalink.org) at MHA. It would be helpful if you could email questions in advance of the
conference calls to hcqcc@state.ma.us so that we can prepare.

Thank you for your contribution towards a successful launch of the Council’s health care quality and
cost website.

Sincerely,




Katharine London
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Executive Director

				
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