This document was prepared by Paul Francis, the Chairman of the Step Two Policy Project, and Sally Dreslin, the Executive Director of the Step Two Policy Project.
The complete whitepaper with appendices (PDF), as well as a separate Data Comparison Crosswalk (XLS) is available below.
We want to thank Lauren Peters, the Executive Director of the Center for Health Information and Analysis, and Denny Brennan, the Executive Director of the Massachusetts Health Data Consortium, for speaking to us in connection with this paper. We also want to thank Isaac Michaels, MPH and Hope Plavin, MPA, MHCDS for their invaluable assistance in developing the data crosswalk and the information comparison that accompany this paper.
I. Executive Summary
The thesis of this paper is that the lack of a comprehensive health data, information, and policy analysis infrastructure hampers the ability of policymakers in New York to improve both the healthcare delivery system and health outcomes for individuals. By contrast, Massachusetts has had a comprehensive infrastructure of this type for more than a decade. New York could rapidly improve its own infrastructure by using the Massachusetts model as a detailed road map for changes in New York.
We are using the term “health data” to refer to raw data that is reported to or shared with governmental entities, or quasi-governmental entities such as the regional Qualified Entities (QEs) that supply data to the Statewide Health Information Network for NY (the SHIN-NY) and its parent organization, the New York e-Health Collaborative (NYeC). Health data encompasses everything from detailed claims and payment data from payers and providers to patient level clinical data.
We are using the term “health information” to refer to categories and concepts that are meaningful for the analysis of healthcare operations and the evaluation of policies (e.g., expenditure trends, the case mix index, etc.) that have been derived from raw or “unrefined” health data.
In Massachusetts, two governmental entities and a private data consortium comprise the three legs of the health data, information, and policy analysis infrastructure stool. The most important of these entities is the Center for Health Information and Analysis (CHIA), which has the statutory authority to collect a wide range of raw data elements from the most important participants in the health care delivery system, including hospitals, behavioral health providers, and long-term care facilities, as well as a significant amount of data from commercial insurance plans and public payers. CHIA converts this data into well curated and intuitively presented health information to present a comprehensive picture of the most important aspects of the Massachusetts healthcare delivery system.
The Massachusetts Health Data Consortium (MHDC) is a private member organization that is complementary to CHIA. MHDC was founded in 1978 to perform the data analyses that CHIA performs today. At the time, no state agency was charged with analyzing health system data. MHDC was created to be a neutral third party (i.e., not a provider or payer association) to perform this work. Today, MHDC uses the case mix data and other information that CHIA collects from hospitals to assist hospitals in conducting further analyses as part of their strategic planning efforts. MHDC also serves a valuable role as a convening organization of health data stakeholders to address data governance and other issues that require coordination and collaboration.
MHDC facilitates access to information from CHIA and combines it with third party data, especially from the Lown Institute Hospitals Index, in order to further refine CHIA information into a user friendly and even more comprehensive dashboard of health information for strategic planning and other purposes. MHDC and a private analytics firm developed an analytical tool called Spotlight Analytics which hospitals and other members of the consortium use to benchmark their performance across a wide range of metrics.
The Massachusetts Health Policy Commission (HPC), along with a re-purposed CHIA, was created by statute under Chapter 224 of the Acts of 2012. HPC and CHIA are independent agencies, although CHIA is part of the HHS Secretariat, and have an organizational structure that is analogous to a public authority in New York. HPC has an 11-member Board of Commissioners, two of whom are ex-officio, three of whom are appointed by the Governor, three by the Attorney General, and three by the State Auditor. CHIA has an 11-member Oversight Council, four of whom are ex-officio, three of whom are appointed by the Governor, two by the Attorney General, and two by the State Auditor.
The organizing principle of the HPC in 2012 was the establishment of an annual total health expenditure growth target for Massachusetts. Although the health expenditure growth target continues to be the organizing principle for HPC, the analytical and policy work done by the HPC is also applicable to the goals of measuring access and achieving efficiency to promote the financial sustainability of providers in the health care delivery system.
Our view is that the issues of affordability and access/provider financial sustainability are really two sides of the same coin. In New York, given the primacy of concerns related to access and the financial sustainability of providers, a permanent health policy research entity should focus on analysis of health issues with a governance and staff infrastructure similar to the HPC, but with an explicit objective of addressing not only affordability, but also access and financial sustainability.
A permanent health policy research body in New York would be complementary to, and not a substitute for, a temporary Healthcare Delivery System Reform Commission of the type described by Governor Hochul in the 2022 State of the State. A temporary Health Care Delivery System Reform Commission, the planning for which reportedly is well underway, could focus on a strategic vision for the health care delivery system while also making recommendations for near-term tactical decisions. The temporary Healthcare Delivery System Reform Commission could identify specific areas that require long term and/or more in-depth research to operationalize the vision of restructuring of the health care delivery system, which a permanent health policy research body would have the time and manpower to undertake.
Developing the type of health data, information, and policy analysis infrastructure advocated in this paper is not an immediate solution to a short-term problem. Rather, it is about creating a permanent infrastructure that will improve the health care delivery system in New York for decades to come. We regard having such an infrastructure as a necessary, albeit not a sufficient condition, of facilitating the far-reaching structural changes that are needed to ensure a strong healthcare delivery system in New York.
Implicit in the emphasis we are placing on having this health data, information and policy analysis be transparent to the public and user friendly is the conviction that democratization of the analysis of this information will produce better outcomes than an opaque system understood only by a few State policymakers and large stakeholders.
This paper concludes with high level recommendations regarding changes needed in New York to rapidly develop a health data, information, and policy analysis infrastructure similar to that of Massachusetts. A future paper could address the specific statutory, regulatory, and organizational structure that it would require.
Appendices A and B to this paper include a detailed crosswalk between the health data available to the CHIA and whether comparable health data is available in New York, and also provides a comparison of the health information that is produced by CHIA, by virtue of their data, and whether that information is available publicly in New York.
II. Introduction
It may be apocryphal that Mikhail Gorbachev once said, “before you can have perestroika, you must have glasnost.” But there is a lot of truth to the proposition that before you can effectively restructure the system, you first must have openness and transparency, so you understand the problems you're trying to fix.
The premise of the Step Two Policy Project is that by understanding the system and presenting fact-based analyses in support of policy recommendations, we can positively contribute to policy reforms in New York. With that in mind, it made sense to us to begin what will be an ongoing series of papers on health policy in New York by addressing the need for increased transparency of health data and the enhanced communication of useful health information based on that data.
As described above in the Executive Summary, we are using the term “health data” to refer to raw data that is reported to and shared with governmental entities, or government-adjacent entities such as the regional Qualified Entities (QEs) that supply data to the Statewide Health Information Network for NY (the SHIN-NY). Health data encompasses everything from detailed claims and payment data from payers and providers to patient level clinical data.
We are using the term “health information” to refer to categories and concepts that have been derived from raw or “unrefined” health data that are meaningful for the analysis of healthcare operations and policies, such as health expenditure trends, the case mix index, and a wide range of other metrics.i
When we talk about “democratization”, we are referring to the goal of making health data and information easily available to policy analysts, healthcare stakeholders, and other members of the public, so that they can do their own analyses. Such a democratization would be important even in the absence of new analytical tools, but advances in machine learning and generative artificial intelligence (AI) greatly expand the potential for the development of important insights if the data and information necessary to build analytical models for AI are made widely available.
New York State government regulates a healthcare ecosystem that is roughly $300 billion dollars in size, but compared to best practice states such as Massachusetts, policymakers in New York are forced to fly the plane relatively blind. It's impossible to quantify the opportunity cost in terms of access, financial sustainability, and affordability that results from this lack of a comprehensive health data, information, and policy analysis infrastructure in New York, but our belief is that the cost is substantial indeed. It is interesting to note that in 2022, New York’s overall ranking in America’s Health Ranking Annual Report was 23rd. This is lower than four of our five bordering states. Those four neighboring states that ranked higher all have a more robust health data and information infrastructure than exists in New York. These states include Massachusetts (second), Vermont (third), Connecticut (fourth), and New Jersey (13th).ii
When CHIA was established in 2012, its primary goal was to centralize the health data collection and analysis efforts across multiple state agencies, give the government a single point of access to objective health data and analyses. In contrast, health data and information in New York are often inaccessible, even when the underlying data theoretically is publicly available. In part, this is because responsibility for the collection and presentation of health data and information remains siloed among multiple State agencies that share regulatory oversight over the New York health care delivery system, including the Department of Health, the Department of Financial Services, and the “O” agencies such as the Office of Mental Health and the Office for People with Developmental Disabilities.iii
All these agencies inevitably approach issues from the parochial standpoint of their own stakeholders, as opposed to recognizing that an integrated approach is essential to effective management of the healthcare delivery system. This balkanization of responsibility not only hinders the efforts of policymakers to design policies that promote overarching goals for the healthcare delivery system, but also undermines efforts to implement integrated healthcare solutions, such as those that are necessary to better serve individuals with complex needs that cross siloed service sectors.iv
The topic of transparency of “health data, information, and policy analysis” is too broad to tackle in a single paper. This initial paper focuses primarily on the availability of health data, information, and policy analysis at a level that can assist providers and policymakers.
Subsequent papers will address related issues that are more focused on the health data and information infrastructure necessary to optimize population health management and the integration of clinical care. Such issues include the data infrastructure required for population health management at a regional level, alternative payment methods such as value-based payments, and the pros and cons of the New York's existing organizational structure for managing the health information exchange in New York (i.e., QEs, SHIN-NY, and NYeC).
New York has been working for a number of years on enhancing various aspects of its health data infrastructure, including most notably the All Payer Database that has been in development since 2016.v Other efforts designed to improve the availability of useful health information (i.e., useful presentations of information based on the raw data collected) are also underway or under discussion.
As with almost any organization, the natural tendency is to seek to build a comprehensive health data, information, and policy analysis infrastructure from scratch. We are advocating that New York policymakers resist that temptation, because New York can get the infrastructure it needs much more rapidly and efficiently without trying to design a system from a blank sheet of paper.
Instead, New York should adopt as the foundation of its health data, information, and policy analysis infrastructure the model that exists today in Massachusetts through three related entities: the Center for Health Information and Analysis, the Massachusetts Health Data Consortium, and the Massachusetts Health Policy Commission. As the renowned Harvard health economist, David Cutler, who also serves as a member of the HPC Commission, says about this infrastructure:
The data has enormous impact. We know more about the medical system in Massachusetts than any state knows about its medical care system. We have a superb, absolutely superb, data infrastructure from the Center for Health Information Analysis [and the HPC] cost trends team. We know as much as we can know about the medical system from what's happening to costs, to what's happening to measures of utilization, to what's happening to [revenue and profit] margins at different organizations, to what's happening to social determinants of health.vi
To borrow the phrase apocryphally attributed to Pablo Picasso, “good artists borrow and great artists steal.” New York should “steal” the considerable work already done in Massachusetts to form the foundation of the health data, information, and policy analysis infrastructure in New York. Once this foundation is established, New York can customize aspects of it to meet specific policy and program objectives.
III. The Health Data, Information, and Policy Analysis Infrastructure in Massachusetts
Massachusetts arguably places greater emphasis on measuring its healthcare system than any other state. Its health innovation efforts benefit greatly from its robust health data and information infrastructure, which provides more data and information for evidence-based policy making than exists in other states.vii
The easiest way to show the inadequacies of the health data, information, and policy analysis infrastructure in New York is to compare it to what exists in Massachusetts.
The three entities that comprise this infrastructure in Massachusetts, as identified above, are the:
The Center for Health Information and Analysis (CHIA) arguably is the most important piece of the Massachusetts infrastructure, because it collects the data and curates the information on which other parts of the infrastructure rely. Its overarching purpose is to create the factual foundation to support better healthcare policy and program management in Massachusetts.
Non-governmental entities, such as Massachusetts Health Data Consortium (MHDC) build analytics based on the CHIA data and information. Finally, the Massachusetts Health Policy Commission (HPC) institutionalizes the process of seeking continuous improvement by providing substantial analytical resources and a framework for translating evidence based insights from health data and information into policies and program enhancements that strengthen the health care delivery system.
Center for Health Information and Analysis
CHIA, as an independent agency, was created in 2012 under the same statutory provision as HPC, to provide the health data and information necessary to support evidence-based program and policy decisions. CHIA has a different governance structure than that of HPC.viii CHIA is overseen by the Health Information and Analysis Oversight Council (the Oversight Council), which is responsible for its budget and provides guidance on research and analysis conducted by CHIA. The Oversight Council is an 11-member body that was established in the FY2016 Final Budget, and meets quarterly. CHIA is managed by an Executive Director, who is appointed by a majority vote of the Governor, Attorney General, and State Auditor. The Executive Director and Oversight Council members serve five-year terms and can be reappointed.
In contrast to New York, where multiple agencies have the authority to collect health data, CHIA has the statutory authority to collect data reports from payers and providers on a wide range of health care statistics and data. As such, CHIA serves both as the agency of record for Massachusetts health data and the primary source of health information and analytics that support program management and policy development in Massachusetts. In short, it is the primary resource in providing health information necessary for fact-based research on health related issues for the Executive, the Legislature, the Attorney General, and the State Auditor.
Although the description below endeavors to explain the health data and information available through CHIA, the best way to understand what CHIA provides is to review its website and its Annual Report on the Performance of the Massachusetts Health Care System. The Annual Report is a well-organized and well-written 142-page report with clear tables on the key measures of healthcare delivery in Massachusetts. The tables include not only high-level metrics, such as Total Health Care Expenditures by payer type and service category, but also curated metrics that illustrate meaningful trends within the changing healthcare environment. Appendix A to this paper, the Information Comparison Crosswalk – Massachusetts CHIA and NY, includes the Table of Contents of the Annual Report, which shows the comprehensive nature of health information that CHIA makes available to the public.
CHIA converts the “unrefined” health data it collects into a well curated set of health information metrics that provide a comprehensive picture of the most important aspects of the Massachusetts healthcare delivery system, including provider, payer, and population health dynamics. Data refinement is the process of transforming raw and unstructured data into clean and structured formats. The purpose of data refinement is to enhance the usability and relevance of data, so that the data can be accessed, analyzed, and interpreted by stakeholders.
Although a single statistic is easier than raw data to interpret, many more analyses and insights can be derived from raw data than can be derived from a single statistic. Because this tradeoff is inherent, CHIA adheres to a best practice for achieving transparency by publishing the data in multiple formats that span levels of refinement including the lowest level of refinement that can be shared publicly. For each health information metric, CHIA also provides an Excel spreadsheet that includes the “unrefined” health data and “semi-refined” health information datasets, which enables further independent analysis by any interested party. The “Data” section of the website shows that CHIA organizes the data it collects into three primary buckets: the Massachusetts All Payer Claims Database; Hospital and Other Provider Data (which includes payer information); and a wide range of data categorized under Case Mix Index. The “Health Information and Analysis” refines that data information into useful metrics in the following categories: Hospital Care, Costs & Payments; Quality & Patient Safety; Access to Insurance & Use of Care; and Health System Performance.
The Case Mix section includes the Massachusetts Acute Hospital Case Mix Database is a database comprised of the Hospital Inpatient Discharge Database, Emergency Department Database and Outpatient Observation Database. For each of these databases, CHIA provides a detailed manual describing the data elements and provider-specific notes regarding potential data integrity issues.ix
New York collects much of this information as well, although it is much less accessible than the user-friendly format of CHIA. The difficulty of accessing this information in New York is a reflection in part of the information being held in multiple databases which are managed by different agencies who often resist making the information available to other agencies come up much less the public.x It is important to emphasize, however, that simply making more data publicly available would have limited impact unless the data is organized and curated in a fashion that provides meaningful health information that frequently cuts across different silos within the health care delivery system.
The Step Two Policy Project has created a document titled: Data Comparison Crosswalk – Massachusetts CHIA and NY ("Data Crosswalk") included as Appendix B to this paper. The document is subject to change based on feedback and we are committed to updating the comparison on an ongoing basis. If the relevant New York agencies or others are able to contribute to the Crosswalk, it will be an even more complete road map for a health data and information architecture.
The Data Crosswalk shows that New York collects some, although not all, of the raw health data collected by Massachusetts, but there is a significant difference between the level of refined health information conveniently made available to the public in Massachusetts through the CHIA compared to what is available in New York in multiple data locations managed by different State agencies. As a result, it is much easier to get an overall understanding of the health care delivery system in Massachusetts than is the case in New York.
Examples of useful health information curated by CHIA include such measures as the “Payer Reported Commercial Rebates as a Percentage of Gross Pharmacy Expenditures,” the “Growth in Telehealth Expenditures,” and “multi-source acute hospital financial data sets” showing financial information about cost, revenue, financial performance, payer mix, utilization and other hospital characteristics. CHIA has also developed an index called the “Statewide Relative Price,” which shows both price variation in the prices that providers charge consumers, as well as variation in the commercial market in the amounts that payers reimburse providers. The issue of price variation in New York was examined in 2016 in a study partially funded by the New York State Health Foundation, and a private not-for-profit organization called Fair Health presents certain information on this issue, no governmental entity regularly tracks price variation from a consumer or provider perspective despite the major role price variation plays in access, sustainability, and affordability.xi
The table below summarizes some of the major categories of reporting in the CHIA Annual Report and describes ways in which CHIA utilizes this data is shown in the table below:
CHIA also curates and presents a useful profile of every hospital facility in Massachusetts, with key metrics in such areas as “at a glance” statistics, services, quality, utilization, patient revenue, trends, and financial performance.xii Appendix C shows the profile for a midsize community hospital.
The critical question, of course, is whether the existence of this greater visibility into health data and information actually benefits the healthcare delivery system. CHIA has a monthly newsletter called “Data Matters” expressly to reinforce the point that access to good health data and information does, indeed, matter. Massachusetts policymakers and outside experts (as reflected in the comment from David Cutler above) strongly believe their ability to make more evidence- based decisions because of the health and daily infrastructure improves public policy.xiii Conceptually, the transparency and accessibility of health data and information should enable more objective analysis and serve as a basis for well-informed policy formation and healthcare decision making.
Massachusetts Health Data Consortium
The Massachusetts Health Data Consortium (MHDC) was founded in 1978 to collect the kind of data now collected by CHIA to serve as a neutral third party to engage with all stakeholders on data issues. MHDC today is the non-governmental, industry-facing entity that provides analysis, data governance, health information exchange, and the convening of industry to seek to ensure that necessary changes to the health data infrastructure, especially regulatory ones, happen.
MHDC groups services into three categories: analytics, data governance (e.g., standardization and interoperability), and exchange of administrative health data. MHDC’s services address the “myriad innovations in data science and analytics, data standardization and exchange, and the governance of a health data economy that puts the individual at its center.” As the MHDC website states: “The opportunities for healthcare providers and health plans to innovate and create more value for patients are rooted in sharing all health information between providers, payers, and patients. This democratization of health data will give patients and their caregivers the knowledge and tools to make the best choices for each patient based on each of their specific needs.” (Emphasis added)
The role of MHDC in providing a comprehensive health data, information, and policy analysis infrastructure may be less central than the contributions of CHIA and HPC, but MHDC serves an important function in helping to translate the data from CHIA and the policy insights from HPC into improvements of the Massachusetts health care delivery system, as well as convening the community to implement technology and data-related initiatives. While it is less clear how the MHDC services should be translated to New York, understanding the tools it gives to providers and others should help to illuminate that question.
MHDC works closely with CHIA. MHDC does not collect any data other than from CHIA, the state of Rhode Island, and The Lown Institute, a not-for-profit health information provider that collects information from CMS and other third-party datasets to create the national Lown Institute Hospitals Index for Social Responsibility. Instead, MHDC organizes these data into dashboards that hospitals and health systems use to support strategic planning and other analytical work.
The information dashboard maintained by MHDC is paired with an analytics tool that assists hospitals and other providers in strategic planning and benchmarking their operations compared to similar hospitals in Massachusetts. The analytics tool, called “Spotlight Analytics” Was developed in partnership with a private healthcare analytics firm. It includes comprehensive case mix and market share data from the CHIA and comprehensive equity, outcomes, and quality measures from the Lown Institute's Hospitals Index. The Spotlight Analytics service also provides analyses of patient origin, disease prevalence, cost of care, and comparative costs and outcomes for every acute care hospital in Massachusetts and Rhode Island. With the Lown Institute data, Spotlight Analytics also provides data on how Massachusetts providers rank and compare to each other in health equity, clinical outcomes, and value of care.
The following are the types of information found on the MHDC dashboard:
MHDC also includes significant educational components for users of health IT. For example, MHDC worked with the Network for Excellence in Health Innovation (NEHI) to prepare a major policy analysis designed to enable Massachusetts to take a leadership role in adopting automated prior authorization solutions. Its 65-page Report was an actionable plan to standardize required activities for automated prior authorization while accounting for the Massachusetts regulatory, payer, provider, and technology environments.
Massachusetts Health Policy Commission
As noted above in the Executive Summary, the organizing principle of the HPC was the establishment of an annual total health expenditure growth target for Massachusetts.xiv The HPC is supported by a staff of 60 professionals, including data and policy analysts. According to a study by the Commonwealth Fund, “Stakeholders generally expressed respect for the expertise of HPC staff, the quality of its research, and the credibility of which helps to build consensus on the facts underlying potentially contentious policy issues.”xv The HPC spends approximately $10 million a year on policy analysis and research staff to produce its annual report on cost trends and to conduct other deep dive analyses on a wide range of issues. Although the HPC is nominally an independent agency and is responsive to legislative input and questions, it is also closely integrated with the executive branch’s health policy and budget apparatus. By statute, the equivalent of New York’s Deputy Secretary for Health and the Director of the Budget are ex officio members of the HPC board.
HPC and CHIA share responsibility for monitoring health care spending in Massachusetts and annually measuring performance against the state’s health care cost growth benchmark. For example, ahead of HPC’s annual Health Care Cost Growth Benchmark Hearing, a public hearing that considers available data, information, and testimony regarding whether modification of the Health Care Cost Growth Benchmark is appropriate, CHIA issues its Annual Report on the Performance of the Massachusetts Health Care System. At the Benchmark hearing, CHIA staff present findings from their Annual Report, which examines trends in costs, coverage, and quality indicators to inform policymaking; and information related to provider and payer financials; and commercial insurance enrollment and premium and cost-sharing trends.
The consulting firm Mathematica conducted an in-depth review of HPC in 2022 based on interviews with 50 stakeholders. Mathematica concluded that there seems to be a general consensus that the health expenditure growth target in Massachusetts constrained overall expenditure growth over the first half of the life of HPC as payers and providers used the expenditure target as a reference point for their price negotiations.xvi Since then, however, the “sentinel effect” of the health expenditure growth target has diminished and health expenditure growth in Massachusetts has exceeded the target.xvii
In addition to compiling a comprehensive annual cost trends report and identifying opportunities for savings, the agency publishes focused analyses on specific topics such as variation in the performance of provider organizations, improving the care of patients with co-occurring disorders, and the effects of “boarding” patients with behavioral health issues in emergency departments.xviii Other examples of how the analytical focus of the HPC and its staff goes beyond just reviewing healthcare expenditure growth include the full chapter in the 2022 Health Care Cost Trends Reportxix devoted to addressing changes in ambulatory care patterns in children and adults between 2018 and the onset of the COVID-19 pandemic in 2020, “Sidebars” in the annual report examining spending on clinician-administered drugs, and reports and policy briefs on such esoteric topics as children with medically complex conditions, consolidation and closures in the pediatric health care market and certified nurse midwives and maternity care.xx
One reason that New York has never embraced the health policy commission idea is that a state health expenditure growth target has long been opposed by healthcare stakeholders, who believe such a target would overshadow the concerns about access and financial sustainability. We share that concern. Indeed, the primacy of concerns related to access and the financial sustainability of providers in New York would make it imperative that a permanent health policy research authority would focus on some of the same analytical issues as the HPC, but with an explicit objective of addressing not only affordability, but access and financial sustainability as well.
Because we think the underlying drivers of the issues of access, sustainability, and affordability are largely the same, we strongly believe that a permanent health policy research body in New York would develop insights to improve the overall economics of the healthcare delivery system, with efficiency gains divided among the goals of expanding access, promoting provider financial sustainability, and cost savings for health consumers. A subsequent paper will discuss in more detail how New York could create a nuanced index that takes into account all three of these related issues rather than simply focusing on health expenditure growth.
In addition to evaluating performance of the healthcare delivery system for Massachusetts as a whole, HPC uses CHIA data and information to annually review individual payer and provider spending performance. HPC has the authority to require payers and providers with excessive spending growth to implement a Performance Improvement Plan (PIP) although HPC has only once required a health system to implement PIP to reduce spending.xxi As is the case with the health expenditure growth target generally, it's unlikely that New York would choose to confer this type of authority on a permanent health policy research body. But at the same time, the PIP construct and analytical approach would create a formal structure for New York 's efforts to improve the performance of financially distressed hospitals.
Much of this performance improvement work is managed through the Care Delivery Transformation (CDT) Committee of the HPC, which is responsible for “advanc[ing] the HPC’s mission to develop strategies to promote care delivery and payment system transformation…” CDT’s focus areas include oversight of the HPC’s certification and investment programs; learning and dissemination activities; program evaluation; expansion of alternative payment methods (APMs); quality measurement alignment and improvement; and support of related research.”
According to David Seltz, the Executive Director of the HPC, one of HPC’s primary objectives is to expand Medicaid health policy reforms to the commercial market. New York has found it difficult to advance this type of alignment between public and commercial payers. A permanent health policy research body with a clear mandate to take a holistic and integrated approach to improving all aspects of New York's healthcare delivery system could prove more successful than siloed regulatory agencies that inevitably seek to protect the interests of their stakeholders.
The HPC also performs other functions that are already performed by the New York State Department of Health or the Public Health Planning and Policy Commission (PHHPC) in New York. For example, the HPC analyzes consolidations within the health sector to assess whether they would lead to higher prices. The HPC also plays a quasi-regulatory role in certifying various aspects of the healthcare delivery system, such as accountable care organizations and digital health eligibility. New York would not need to burden a permanent health policy research body with these responsibilities.
Finally, a permanent health policy research entity in New York would be complementary to, and not a substitute for, a temporary Healthcare Delivery System Reform Commission of the type described Governor Hochul in the 2022 State of the State. A temporary Health Care Delivery System Reform Commission, planning for which reportedly is well underway, could focus on a strategic vision for the health care delivery system while also making recommendations for near-term tactical decisions. Such a strategic vision could identify specific areas that require long term in-depth research to operationalize the complicated restructuring of the health care delivery system.
IV. Conclusion And Recommendations
The development of a comprehensive health data, information, and policy research infrastructure is not a short-term fix for the challenges facing healthcare in New York. Rather, it is a legacy investment in infrastructure that is a necessary, albeit not a sufficient, condition for the effective and far-reaching restructuring of the health care delivery system in New York that will be necessary to ensure access, quality care, financial sustainability for providers and affordability for consumers.
Our specific recommendations are as follows:
New York should create a new governmental entity that would have overall responsibility for the collection of health data and reporting of health information at a level that is equivalent to the Massachusetts Center for Health Information and Analysis. There are significant advantages to investing in a single governmental body with the authority to collect health data from all aspects of health care delivery system in New York, including providers and payers. In the short run, however, New York could continue to have multiple agencies collect this data and have the New York health information and analysis entity synthesize that information in a data and information architecture similar to CHIA. For health data that is not currently collected in New York, but which is important to the health information and analysis infrastructure, the State should expand the collection authority of existing agencies or directly confer that authority on the New York health information and analysis entity.
New York should create a permanent health policy research body that engages in the types of research and analysis activities conducted by the Massachusetts Health Policy Commission. However, unlike Massachusetts, the organizing principle for a permanent health policy research body in New York should be the threefold goals of access, provider sustainability, and affordability.
A permanent health policy research body in New York should be complementary to, and not a substitute for, a temporary Healthcare Delivery System Reform Commission of the type described Governor Hochul in the 2022 State of the State. A temporary Health Care Delivery System Reform Commission should be helping to develop a strategic vision for the health care delivery system. Such a strategic vision inevitably will identify specific areas that require ongoing, long term and in-depth research to operationalize the complicated restructuring of the health care delivery system that such a vision is likely to require.
In order to avoid the balkanization of health data and information, it is essential that both the New York health information and analysis entity and the permanent health policy research body in New York are organizationally above the multiple state agencies that regulate different aspects of the healthcare delivery system in New York. There are strong advantages in making these entities public authorities in order to give them flexibility they need to rapidly scale organizations that will probably require more than 100 professionals from different disciplines. The public authority structure would also provide representation beyond the executive branch, although (consistent with other public authorities in New York) the governor would control a majority of the appointments. It is essential that these entities must become well integrated into the policy and budgetary mechanisms of the executive branch, although they would also provide information to the legislature consistent with the principle of democratization of policy analysis. Although there are significant benefits to creating these entities in the form of public authorities, if they can only be created as state agencies, they should be independent agencies with a clear mandate to supersede the authority of other state agencies as it relates to the health data, information, and policy research infrastructure.
New York should develop options for ensuring that services of the type offered by the Massachusetts Health Data Consortium are available to providers and policymakers in New York. New York, through the Department of Health, the Executive Chamber and the Division of Budget, already spends considerable resources seeking to benchmark providers in New York against each other and against various best practice standards. Given the inextricably interrelated nature of the healthcare delivery system, New York should consider whether a new public or private entity should be created to more efficiently perform those functions.
Endnotes
i Data refinement is the process of transforming raw and unstructured data into clean and structured formats. The purpose of data refinement is to enhance the usability and relevance of data, so that they can be accessed, analyzed, and interpreted by stakeholders. Data refinement can be applied along a continuum of levels, and in various forms. For example, raw data could be refined sequentially into aggregated line-list data, an interactive dashboard, a static report, a single data-visualization graphic, and then a single statistic. An important consideration is that each successive level of refinement involves a tradeoff between interpretability and flexibility. Although a single statistic is easier than raw data to interpret, many more analyses and insights can be derived from raw data than can be derived from a single statistic. Because this tradeoff is inherent, a best practice for achieving transparency is to ensure that data are published in multiple formats that span levels of refinement – and at least include the lowest level of refinement that can be shared.
ii Seven other states have similarly organized their health data, information, and policy analysis infrastructure around a state health expenditure growth target.
iii There are other State entities that are involved in healthcare delivery in New York whose data may not be publicly available or consistently reported, but which could support important analyses. These include the New York State Health Insurance Program which covers over 1.2 million lives, and the healthcare services provided by the New York State Department of Corrections and Community Supervision.
iv A fully integrated approach to improving health outcomes and the health care delivery system also requires capturing health-related information that reflects social determinants of health. Best practice efforts to develop a “health” data and information infrastructure increasingly will work to capture such information.
v It also appears likely that New York will need to develop aspects of a stronger health data and information infrastructure as part of its pending 1115 Waiver.
vi Ten Years of the Massachusetts Health Policy Commission at 4:50-5:30.
vii See, e.g., “CHIA: Using Data and Analytics to Support Healthcare Policy Center For Health Information And Analysis,” Ray Campbell, Presentation for the Massachusetts Health Policy Forum January 5, 2021. viii The Center for Health Information and Analysis (CHIA) was established under Section 20 of Chapter 12C of the Massachusetts General Laws.
ix CHIA also collects patient-level data from Massachusetts acute care hospitals. Three main data types constitute the Case Mix Database: Hospital Inpatient Discharge Database (HIDD); Outpatient Observations Database (OOD); and Outpatient Emergency Department Database (ED).
xAs described in the CHIA website: “The Case Mix data includes detailed information on inpatient discharges, emergency department visits and observation stays. For each of these patient encounter types, hospitals submit detailed information, including: patient demographics, admission and discharge information, diagnostic and procedural coding, provider details and detailed charge information.”
xi Why Are Hospital Prices Different? An Examination Of New York Hospital Reimbursement, Gorman Actuarial, 2016.
xii see, e.g., Anna Jacques Hospital Profile.
xiii See, e.g., Ten Years of Cost Containment in Massachusetts: A Decade of Advancing a More Transparent, Accountable, and Equitable Health Care System
xv How the Massachusetts Health Policy Commission is Fostering a Statewide Commitment to Contain Health Care Spending
xvii The Massachusetts Health Care Cost Growth Benchmark and Accountability Mechanisms: Stakeholder Perspectives
xviii How the Massachusetts Health Policy Commission Is Fostering a Statewide Commitment to Contain Health Care Spending Growth
xx Although New York's health agencies produce numerous reports in response to legislative directives, the fact that they are not integrated within a broader framework of analysis hampers their impact. At least some of these studies could more effectively be produced by the staff a permanent health policy research entity.xx
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