My name is Bob Davis and I represent the New York State Department of Health where I am responsible for maintaining the Statewide Planning and Research Cooperative System widely known as SPARCS. Clinical and financial data for all inpatient and ambulatory surgery discharges from New York State regulated hospitals is collected from the system founded in the late 1970's using NCVHS recommendations contained in the Uniform Hospital Discharge Data Set and continues to be used for rate-setting, utilization studies, and a wide variety of research projects. I would like to thank the National Committee for inviting me to todays hearing and giving me an opportunity to share our experiences in New York State. The Department is committed to data standards as the full impact of the Administrative Simplification provisions of the HIPAA legislation evolve.
For us attachment information is any data needed beyond what is required by any payer to adjudicate a claim. An administrative data base such as SPARCS will always need certain data items not necessary for payment of a claim, but no less important. To meet our needs without placing an undue burden on providers, our requirements need a home.
Deciding whether that home is in the claim transaction or the attachment transaction, we feel, should be dictated by logic. To illustrate my point, I would like to state two assumptions followed by two examples of how two of our additional data needs could be accommodated in the existing transaction sets.
Ground rule number 1 - All Standards Development Organizations (SDO’s) need to accept the fact that Administrative Simplification can be achieved only when duplication and data redundancies are eliminated at the source, which are the provider information systems. This requires SDO’s to take a global view of information needs for health data.
Ground rule number 2 - Every payer needs to recognize the fact that other data collectors (other payers or state agencies like SPARCS) have different requirements and they should not reject claims because too much information is submitted. Follow the axiom Ignore Don’t Reject.
For instance number one. In NYS two additional discharge status codes are needed to ensure that appropriate provider reimbursement has occurred and to enrich research. The two additional codes are for transfers of babies with low birth weight and transfer of trauma patients to regional hospital centers. Currently, the National Uniform Billing Committee maintains an external code list and argues that these codes are not needed to adjudicate a claim. I agree, but that does not lessen the importance of this information. The question remaining then Is it logical for providers to have to maintain two discharge status coding schemes to support these additional and useful codes. I think the answer is Definitely Not, and the logical place for these codes is with already defined discharge status codes.
For instance number two. As recommended by the NCVHS core data elements and the UHDDS before, NYS and California collect a diagnosis indicator to determine the presence or absence of a diagnosis before admission to the hospital. While the 837 transaction set provides for the collection of several other diagnosis codes, there is no room for these associated indicators. A slight change in the implementation guide or minimal data maintenance to one data segment will allow for a logical and manageable means for collecting this information. Does is make sense for providers to duplicate all the diagnosis information just to avoid collecting this one character piece of information for each diagnosis on the claim transaction. Again I think the answer is Definitely Not.
There are obviously other data elements needed for public health research systems that are not in the existing claim transaction that do need a home of their own. The New York State Department of Health is hoping that the attachment transaction set is robust enough to accommodate these additional data needs. The New York State Mdicaid Program is also under the auspices of the Department of Health. In addition to the issues I mentioned related to SPARCS, the state Medicaid program also has additional data needs related to the claim and our ability to comply with state and federal requirements that are presently legislated or regulated.
As a participant in the process, I know one essential ingredient to make this feasible is the electronic staple between the claim and attachment transaction sets. With the ability to link various transaction sets, we feel the real issue of standardizing data content for all justifiable uses can become the main focus of SDO’s in order to achieve administrative simplification at the source - provider information systems.
I was fortunate to be invited to a meeting sponsored by NCHS and CDC on January 23rd that brought together several organizations that shared a common need for additional data beyond claim transactions, including NAHDO. It was very encouraging that there was unanimous consensus at that meeting to move forward to sponsor a workshop that would broaden the base of parties interested in bringing standardization to these “additional” data needs.
I personally want to thank the NCVHS on behalf of the New York State Department of Health for giving us the opportunity to share our committment to standards as a way to make better decisions on relevant health care issues of today and on into the future. It is obvious from the “questions for presenters” I received along with my invitation to speak at this hearing that much thought has already preceeded these hearings and that there is a strong desire to solicit industry input to achieve consensus solutions to the complex but important data issues confronting us today. This effort will serve to better prepare the country for tomorrow’s health crises in an affordable way. Thank you again for your leadership and an opportunity to express our views.