Hospital Association of Pennsylvania > Advocacy > Federal Advocacy > HAP Comment Letter on NQF Draft Report on Risk Adjustment for Socioeconomic or Other Sociodemographic Factors


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HAP Comment Letter on NQF Draft Report on Risk Adjustment for Socioeconomic or Other Sociodemographic Factors

April 15, 2014

Christine Cassel, MD
President and Chief Executive Officer
National Quality Forum
1030 15th St NW, Suite 800
Washington, D.C. 20005

RE:  National Quality Forum Draft Report: Risk Adjustment for Socioeconomic Status or Other Sociodemographic Factors

Dear Dr. Cassel:

On 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 patient outcomes.

If 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.

Further, 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.

Additionally, 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.

Pennsylvania 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.

CMS 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.


Senior Vice President
Policy & Regulatory Services

c:  Patrick Conway, MD, CMS

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