HAP Comment Letter on NQF Draft Report on Risk Adjustment for Socioeconomic or Other Sociodemographic Factors
and Chief Executive Officer
15th St NW, Suite 800
Quality Forum Draft Report: Risk Adjustment for Socioeconomic Status or Other
behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP),
which represents approximately 240 member institutions, including 125
stand-alone hospitals and another 120 hospitals that comprise 32 health systems
across the state, we appreciate this opportunity to comment about the National
Quality Forum’s (NQF) draft report on risk adjustment for socioeconomic or
other sociodemographic factors.
HAP strongly supports
the recommendations in this report, particularly the need for risk adjustment
for sociodemographic factors. We believe that this is needed to compare
provider performance appropriately.
HAP urges NQF members
to support the recommendations of the NQF Committee, and we urge The Centers for Medicare & Medicaid Services (CMS) to immediately recognize the need to
improve the outcome measures being used in the Medicare program. We believe
that outcome measures used to assess health care provider performance for
public reporting and pay-for-performance programs should be adjusted for
sociodemographic factors, as research demonstrates these factors link to
such adjustments are not made, hospitals and health systems are inappropriately
being held fully accountable socio-economic factors and the resulting lack of
appropriate resources in the communities they serve. Payment systems built from
unadjusted measures will unfairly limit reimbursement to those serving
disadvantaged communities, reducing their ability to provide needed services to
their patients, while rewarding providers serving advantaged communities.
the public could be misled into believing the care provided by those serving
disadvantaged communities is of lesser quality than it actually is, and that
the care provided by those serving the most advantaged populations is better
than it may actually be.
we agree with the report that when measures are used for the purpose of
understanding disparities in health and health outcomes, it would be
inappropriate to adjust for sociodemographic factors because that would mask
the very disparities the policymakers want to see. As suggested by the examples
used in the report, we believe that calculating the adjustment for
sociodemographic factors will serve to highlight the differences in outcomes
that are associated with community factors. This will enable communities,
working with human service organizations, health care providers and others, to
better address these factors.
hospitals and health systems are working collaboratively with community
organizations and other health care providers to reduce preventable
readmissions. The results of that work—reflected in the progress of hospitals
participating in the Pennsylvania Hospital Engagement Network—are significant.
The hospital community is looking beyond its individual organizations to
improve care coordination. However, there also is recognition that
sociodemographic factors can affect patient outcomes and readmissions, which
are not easily addressed.
already publishes data about hospital mortality and readmissions rates, and
includes those measures in calculating payment rewards and penalties. As health
services researchers and the Medicare Payment Advisory Commission have found,
the current calculation of these measures does not adjust for sociodemographic
factors. Therefore, a disproportionately large number of hospitals serving
low-income communities are portrayed as having bad results and are incurring
payment penalties. This is leading to diminished resources for those serving
the neediest communities and most vulnerable patients.
Again, we support the recommendation of the NQF Committee to risk
adjust for socio-demographic factors. This will result in a more accurate
comparison of the quality of care and ensure that hospitals are being measured
by the same standards for reimbursement purposes.
Thank you for the opportunity to review and comment about the risk
adjustment for socioeconomic status or other socioeconomic factors. If you have any
questions, please feel free to contact me
at (717) 561-5344, or Brian Smith,
director, clinical compliance and quality, at (717) 561-5356.
& Regulatory Services
Conway, MD, CMS