Wednesday, May 15, 2013

Apologies to CHIA and Commissioner Boros

I was dramatically wrong in a recent blog post when I suggested that the MA Center for Health Information and Analysis had failed to make broadly available an all-payer claims database.  I apologize to the agency and to Executive Director Áron Boros.  I print below the full text of a reply from Commissioner Boros which, for some reason, I did not receive earlier.  I'd like to offer a reasonable excuse for my error, but--having done a root cause analysis--can best attribute it to the equivalent of diagnostic anchoring.  I believed that CHIA had not acted to free the data.  I conducted a (clearly incomplete) web search for information on the topic and found nothing to suggest an alternate view, so I concluded that I was correct.  A good lesson all around.

Here's Commissioner Boros' complete comment to me, which will also be posted on the original site, along with an addendum by me in the text.

Paul,

While I appreciate your continued advocacy for transparency and, in particular, your focus on patients, I am concerned that this post does not reflect any research on your part into the current state of transparency in Massachusetts.

My agency, the Center for Health Information and Analysis (CHIA), is responsible for collecting, enhancing, and sharing the data in the all-payer claims database (APCD), among many other data sets.  You are wrong when you state that CHIA has “failed to act.” Even a cursory look at our website would confirm this.  www.mass.gov/chia/apcd

Since July of 2012, the all-payer claims database has been available for public release.  Applications to use this data are posted to our website (at http://www.mass.gov/chia/researcher/health-care-delivery/hcf-data-resources/apcd/accessing-the-apcd.html).  There, you can see that we have handled more than 15 applications in the last 9 months. The first one is dated July 13, 2012.  The applications come from a wide variety of researchers and other users, and address a number of interesting policy questions. 

We also recently updated the fee schedule for access to the APCD (http://www.mass.gov/chia/docs/g/chia-ab/ab-13-03-apcd-fee-schedule.pdf).  The fee schedule reflects a careful consideration of appropriate pricing for this kind of data including, among other things, a public hearing and comment process. The fee schedule also provides for full or partial fee waivers for a variety of applicants, including students and qualified researchers in certain circumstances. 

I am proud of our accomplishments in increasing data transparency, and confess to a little bit of frustration that your post appears to assume that we have not been working to fulfill this mission without a minimum of research into what has actually happened over the last year.  In addition to the public release, the APCD is currently also being used to help implement to the Affordable Care Act, is being used to support the Division of Insurance in some of its market monitoring activities, and is being used internally by CHIA for health care research and analysis. 

Looking forward, there is much more to come.  As Pat G mentions, last year’s Cost Containment bill provides for new access to the APCD. We are in the process of revising our regulations to reflect the requirements of the new bill, and anticipate releasing a proposed revision in May. Moreover, the APCD will be used over the next 3 years to accelerate other health care reform initiatives, including data sharing with providers under the Executive Office of Health and Human Services’ State Innovation Model grant. http://innovation.cms.gov/initiatives/State-Innovations-Model-Testing/index.html

I would be happy to discuss the APCD with you more.  As should be clear from my comment, there is a lot to say.  

Cordially,
Áron Boros
Executive Director
Center for Health Information and Analysis

3 comments:

Anonymous said...

Good acceptance of responsibility and correction, but the Commissioner's letter prompts 2 questions, which I ask in all innocence and not in criticism:

1. Why does one have to apply to use the database?

2. Why is there a fee to use the database?

thanks,

nonlocal MD

Anonymous said...

Thank you. Will any of this data be made available to the public who might not want to do research but wants to know state and provider rates for medical conditions?

Aron Boros said...

Hello,
Thanks for the questions. The All-Payer Claims Database has an immense amount of protected health information and other sensitive data. CHIA feels a great responsibility to ensure that the data is used in a way that is protective of patient privacy. There are different application requirements for different uses and applicants (see our <a href="http://www.mass.gov/chia/gov/hcf/regulations.html#publichearings”>proposed regulations</a> for the details; there is an open public comment period for these regulations, and we would welcome your formal input), but the overall intent is to promote transparency while also protecting privacy in ways that are consistent with state and federal law. We are currently exploring ways we could provide a truly de-identified, public dataset in the future, as well as investing in ways to make the data more usable for individuals who don’t have the resources of a large organization.

With respect to the fees, we have a statutory obligation to charge <a href=”http://www.mass.gov/chia/researcher/health-care-delivery/hcf-data-resources/apcd/accessing-the-apcd.html#fee_schedule”user fees</a> to defray the cost of providing access to the database. We have designed these fees through an open public process; it’s worth noting that the fees will never cover the full cost of developing and maintaining the database. Instead, a significant commitment from the legislature, and from hospitals and insurers is required to make this resource available. Finally, as I mentioned above, certain parties can apply for reductions in fees.

CHIA is also responsible for a number of other transparency initiatives. We currently publish reports on <a href=”http://www.mass.gov/chia/researcher/chia-publications.html#tme”>total medical expenditures</a>, and <a href=”http://www.mass.gov/chia/researcher/chia-publications.html#relative_price”>relative prices</a> between providers for a generic bundle of services. We are also exploring ways to provide additional cost and quality information to patients. This effort will build on the now-outdated <a href=”http://hcqcc.hcf.state.ma.us/”>website</a> of the Health Care Quality and Cost Council.

Thank you for your continued interest in this unique resource.

Sincerely,

Áron Boros