(Editor’s note, this is in response to a June 8 op-ed by Independence Institute Health Care Policy Center Director Linda Gorman published at Page Two)
Linda Gorman’s recent article about Colorado’s All Payer Claims Database (APCD) painted a picture of the APCD and the potential uses of its data that was at best misleading and, at worst, inaccurate. It’s important that your readers understand the facts. Ms. Gorman makes three major assertions including that the APCD contains medical records, that the APCD is exempt from HIPAA (federal privacy regulations) and that the data released can be easily re-identified, especially in smaller rural areas. She is wrong on all three major points:
1. The APCD contains no medical records, only administrative claims information.
2. The APCD has no exemption and fully complies with all HIPAA, federal and state privacy requirements.
3. The privacy and data release policies are specifically structured to avoid any re-identification including processes to suppress data in areas of small population.
Before presenting those facts, though, I’d like to offer some context. The news is riddled with stories of frustrations over the cost of health care and the lack of transparent information available to patients and employer purchasers. Look at the responses to the recent Time magazine article about bloated hospital costs, and the release of Medicare information about the wide variations in hospital pricing: consumers are aghast at high and wildly varying prices, especially in light of little information about quality.
The Colorado APCD is an essential tool for identifying differences in price and quality, and enabling consumers to shop for health care services in a free and transparent market.
The APCD was enabled by the Colorado legislature in 2010 following a recommendation from the bi-partisan Blue Ribbon Commission for Healthcare Reform. The Commission and legislators recognized that the APCD could be an important tool to empower consumers and make Colorado’s health care market more efficient. The Center for Improving Value in Health Care (CIVHC), a nonprofit, nonpartisan organization, has responsibility for administering the database and ensuring all federal and state privacy and security statutes and regulations are followed.
Colorado’s APCD is a statewide data warehouse that securely compiles claims data from private insurance carriers, Medicaid and eventually Medicare to provide the most comprehensive picture of health care costs and utilization in our state. High level views of costs of care and use of health care services, using de-identified data, are currently available at www.cohealthdata.org. By the end of the year, consumer-focused price reports will be available on the site, allowing patients to compare out-of-pocket prices (not just charges) by hospital and provider group, alongside quality comparisons.
The APCD is not like the electronic medical record that your doctor keeps to capture and maintain clinical details. It is an aggregated database of encrypted information about health care services paid for by Colorado insurers. Personally identifiable information such as names, Social Security numbers and addresses are removed. Reports and de-identified datasets replace date of birth with an age or age range and reduce zip codes to first three digits (or 000 if fewer than 20,000 people live in that zip code). Reports are aggregated to sufficient size to prevent someone from taking unidentified information and inferring an individual’s identity based on diagnosis or treatment type. This protection, combined with the additional de-identification strategies described above, is of particular value for Coloradans living in small rural communities.
Recent news reports and articles have warned of a Health Insurance Portability and Accountability Act (HIPAA) “loophole” that could be seen as allowing some states to release medical information that could potentially be identifiable. In contrast, under Colorado’s APCD statute and regulations, CIVHC is specifically mandated to comply with HIPAA and the regulations created under that law, including recent updates under the Health Information Technology for Economic and Clinical Health (HITECH) Act.
The Colorado legislation and rules that guide the APCD were designed to provide access to highly aggregated information through a public website and reports. Qualified requesters may, under certain controlled circumstances, also receive reports through a carefully structured data release process that complies with HIPAA requirements. All data requests are reviewed by the APCD’s Data Release Review Committee (DRRC) that was established in accordance with Colorado Department of Health Care Policy and Financing (HCPF) rules to oversee the process of making APCD data available to stakeholders, such as public health organizations and researchers.
In contrast to 10 other statewide APCDs, Colorado’s receives no public funding. Currently, it is funded entirely by grants from Colorado foundations that recognize the value the APCD can bring to the people of Colorado. In order to cover costs of maintaining this valuable resource for Colorado, HIPAA and HITECH-compliant customized reports and data sets that meet the strict requirements outlined above are available for a moderate fee to qualifying entities if used to improve health, improve care and lower costs for Coloradans. While the HIPAA and HITECH rules are complex, they provide a clear mandate to organizations like CIVHC, and we are vigilant to ensure that they are carefully followed and patient information is protected.
We have evidence from our own backyard that thoughtful use of robust data makes a difference. For more than a decade, Mesa County’s providers and payers have used claims data to identify new ways of delivering and paying for health care that have resulted in better outcomes and lower costs for Medicare patients there than in almost any other part of the country.
The APCD represents capitalism at its best: it creates the transparency of pricing and quality that our health care system currently lacks to be an effective market, and it provides information to all of us to make informed decisions about how we spend our health care dollars.
Tracey Campbell is Director of the Colorado All Payer Claims Database at the Center for Improving Value in Health Care. For more information on CIVHC and the Colorado APCD, please visit: www.civhc.org.