P.O. Box 2393 Princeton, NJ 08543-2393 Telephone (609) 799-3535 Fax (609) 799-0005 www.mathematica-mpr.com MEMORANDUM TO: Katie Burns, MDH FROM: Aparajita Zutshi and Eric Schone, Mathematica SUBJECT: Outlier and Reliability Analyses for Hospital Total Care Costs DATE: 6/22/2011 A. Purpose of Memo This memo provides information related to treatment of cost outliers (or extreme high values), various potential reliability thresholds, and implications for minimum sample size criteria. More specifically, it describes the results of using various rules for treatment of cost outliers and reliability for the hospital total care cost analysis. We test a range of thresholds at which to truncate costs and present thresholds that improve explanatory power and reliability but at the same time introduce minimal distortion in costs as measured by a reduction in the proportion of total costs profiled. We do this separately for raw costs and standardized costs, for different payer types (Medicare, Medicaid, and commercial), and different hospital types (prospective payment system [PPS] hospitals and critical access hospitals [CAHs]). We recommend a goal of either moderately high or high reliability (for reasons mentioned below) for hospital profiles based on raw costs and standardized costs, and given this goal and the recommended thresholds, calculate the minimum number of discharges needed per hospital to fulfill the stipulated level of reliability. Finally, we compare these minimum numbers of discharges to the actual distribution of discharges for each payer type and hospital type, and identify the number of hospitals that would be excluded from peer grouping altogether because the hospitals fail to meet the minimum sample size criterion for each of the three payer types as well as the number of hospitals for which a certain payer-specific cost measure might not get reported because the number of discharges available to calculate the measure fails to meet the payer-specific minimum sample size criterion. 1 B. Background Health care cost data is highly skewed, with costs for most patients during any particular time period being low and predictable, and for a minority of patients being high and variable. Due to this skewness, outlier observations can severely limit the explanatory power or the ability 1 A hospital will be included in peer grouping as long as it meets the minimum sample size criterion for at least one payer type. An Affirmative Action/Equal Opportunity Employer MEMO TO: Katie Burns, MDH FROM: Aparajita Zutshi and Eric Schone, Mathematica DATE: 6/22/2011 PAGE: 2 to account for variation in patients’ costs of a regression-based risk adjustment model. A previous memo described this issue in detail and recommended truncating costs to reduce skewness. 2 In this method, costs above a given threshold are replaced with the value of that threshold. Truncating these costs is a way of recognizing that not enough data are available to accurately predict the expected cost for rare high-cost events that can have a disproportionate impact on overall mean costs, which can lead to a single random case distorting the overall ratio of actual to expected cost for a particular practice. This approach, therefore, reduces their impact by imposing a ceiling. It also recognizes that some extreme values may be errors. In addition to improving explanatory power, truncating costs may also be expected to improve reliability (or consistency) because it reduces the total variance in costs. Reliability can be measured as R = Nρ/(1+(N-1)ρ, and is a function of N, the number of discharges attributed to a hospital and ρ, the intraclass correlation (ICC). The ICC is calculated as the ratio of the variance between hospitals’ mean costs and the total variance which is the sum of variance between hospitals’ mean costs and variance within each hospital’s costs. The higher the betweenvariance relative to the total variance (or the higher the ICC), the more reliably profiling can distinguish actual differences in performance between hospitals. Truncating improves reliability by reducing the total variance in costs, which happens through a reduction in the within-variance in costs, unless truncation of outliers disproportionately impacts the mean costs of certain hospitals. Therefore, determining the minimum sample size (N) to achieve a given level of reliability requires measuring the ICC and stipulating the required reliability level. We present the options of using R=0.4, a moderate level of reliability, R = 0.6, a moderately high level of reliability, or R=.8, a high level of reliability, to calculate minimum Ns for raw costs and standardized costs for the two hospital types and the three payer types. We present these potential thresholds of reliability to compare how they balance the need for reliable cost profiles with the need to include the majority of hospitals in Minnesota in peer grouping and performance reporting. 3 Truncation comes at the cost of excluding some recorded expenditures and distorting the actual distribution of costs, and therefore, hospital profiles. The proportion by which total costs are reduced when the threshold is imposed is one measure of that distortion. Therefore, in recommending thresholds we have been mindful of balancing the tradeoff between high 2 Schone, Eric and Aparajita Zutshi. “Considerations in Performing Outlier Adjustments for Hospitals and Physician Clinics—Revised.” Princeton, NJ: Mathematica, April 29, 2011. 3 For more detail on reliability and other statistical issues, please refer to a previous memo - Schone, Eric “Statistical Issues for Reporting Cost Measures in Hospital and Physician Peer Grouping Reports.” Princeton, NJ: Mathematica, December 7, 2010. MEMO TO: Katie Burns, MDH FROM: Aparajita Zutshi and Eric Schone, Mathematica DATE: 6/22/2011 PAGE: 3 explanatory power and reliability and excluding a significant proportion of the health care dollars spent in hospitals in Minnesota. C. Methodology We tested the following truncation rules and evaluated them according to their effects on explanatory power, reliability, and proportion of costs profiled: a. Arbitrary Dollar-value cutoff: Truncate at $100,000. b. Global percentile cutoff: Truncate at 95th, 98th, 99th, and 99.5th percentile based on all discharges for a given cost type, hospital type, and payer type. c. Major diagnostic category (MDC)-specific percentile cutoff: Truncate by MDC at 95th, 98th, 99th, and 99.5th percentile based on all discharges for a given cost type, hospital type, payer type, and MDC. We also compared the effects of these rules to the effects of a model based on untransformed costs. 1. Estimating explanatory power, reliability, and proportion of costs profiled As a measure of explanatory power, we used the R-squared from a discharge-level ordinary least squares model predicting cost as a function of patient characteristics such as age, gender, and ADGs. R-squared is the proportion of variance in the dependent variable (i.e., costs) which can be explained by the independent variables (i.e., age, gender, and ADGs). A higher R-squared implies that the independent variables are good predictors of the variation in the dependent variable. As a measure of reliability, we used the intraclass correlation (ICC) from a hierarchical linear model predicting cost as a function of age, gender, and ADGs, with a random intercept for each hospital. The random intercept captures the individual “effect” of each hospital on the overall variation in costs and explicitly accounts for the possibility that costs within a hospital are likely to be more similar (reflecting the hospital’s effect) than costs across hospitals. This specification allows us to split the the overall variation in hospital costs into two components: (1) variation across hospitals’ mean costs and (2) variation across discharges within each hospital’s costs. The ICC is the ratio of the variation between hospitals’ mean costs to the total variation in hospital costs. Each model was run separately for raw costs and standardized costs for each of the three payer types—Medicare, Medicaid, and commercial, two hospital types—CAHs and PPS hospitals, and for the 10 rules for transforming costs (including the untransformed cost model). MEMO TO: Katie Burns, MDH FROM: Aparajita Zutshi and Eric Schone, Mathematica DATE: 6/22/2011 PAGE: 4 Finally, to calculate the proportion of costs profiled, we divided the sum of truncated costs by the sum of untransformed costs for each truncation rule, cost type, payer type, and hospital type. Appendix A contains a series of tables showing the effect of the different truncation rules and untransformed costs on explanatory power, reliability, and proportion of costs. In general, we find that global percentile cutoffs perform better on explanatory power and reliability (as measured by the ICC) than the MDC-specific percentile cutoffs and only slightly worse on the proportion of costs profiled. Further, we find that the global 99th percentile achieves a reasonable balance between high explanatory power and reliability and a small reduction in proportion of costs profiled. The global 99th percentile also generally performs better than the $100,000 cutoff. However, there are two instances—raw costs in PPS hospitals paid by Medicaid and commercial payers, respectively—where the global 99th percentile ends up excluding much more than five percent of the costs. This happens because these two cost distributions are considerably more skewed than the other cost distributions, with a larger number of very high cost stays in the upper tail of the distribution. Because as a general rule of thumb we do not want to exclude more than 5 percent of costs due to truncation, we recommend making an exception in these two instances and truncating at the global 99.5th percentile. D. Implications for Minimum Sample Size Based on the ICCs from the selected truncation rules for the different cost, payer, and hospital type combinations, we calculated the minimum sample sizes needed to achieve reliability levels of 0.4, 0.6, and 0.8. Table 1 shows these minimum sample sizes along with Rsquared, ICC, and proportion of costs profiled from the selected rules. For reporting of overall and payer-specific hospital costs, we present options of using minimum sample sizes based on either reliability=0.6 (moderately high reliability) or 0.8 (high reliability), while for reporting detailed costs, such as a breakdown by MDCs, we recommend minimum sample sizes based on reliability=0.4 (moderate reliability). As the table shows, the minimum sample sizes increase with the level of reliability. Further, for each level of reliability, the minimum sample sizes required to fulfill that level are higher for standardized costs than raw costs except for the case of discharges paid by Medicaid in PPS hospitals where the opposite is true. Because we want to report reliable values of both types of costs when they are reported, when minimum sample sizes required for standardized costs and raw costs differ, we impose the larger of the two. Therefore, for all hospital and payer types we select the minimum sample sizes for standardized costs as our reporting standards except in the case of Medicaid discharges in PPS hospitals where we select the minimum sample sizes for raw costs as our reporting standards. MEMO TO: Katie Burns, MDH FROM: Aparajita Zutshi and Eric Schone, Mathematica DATE: 6/22/2011 PAGE: 5 Table 1: Effects of Selected Truncation Rules on R-Squared, Intraclass Correlation, Minimum Sample Size, and Proportion of Costs Profiled Proportion of Costs Profiled R squareda Intraclass Correlationb CAHs Medicare Medicaid Commercial All-payer 0.140 0.250 0.207 0.100 0.070 0.065 6 9 10 14 20 22 36 53 58 98.35 98.31 97.56 98.00 PPS Hospitals Medicare Medicaid Commercial All-payer 0.152 0.196 0.206 0.093 0.092 0.100 7 7 6 15 15 14 39 39 36 96.97 96.00 94.67 95.58 0.156 0.283 0.249 0.043 0.059 0.053 15 11 12 33 24 27 89 64 71 98.65 97.94 94.13 96.59 Minimum Sample Size R=0.4 R=0.6 R=0.8 Raw Costs Standardized Costs CAHs Medicare Medicaid Commercial All-payer PPS Hospitals Medicare 0.159 0.072 9 19 51 97.58 Medicaid 0.223 0.196 3 6 16 94.68 Commercial 0.275 0.039 16 37 99 94.80 All-payer 95.75 Note: Except for raw costs in PPS hospitals paid by Medicaid and commercial payers, we used the global 99th percentile for truncating costs. For raw costs in PPS hospitals paid by Medicaid and commercial payers, we used the global 99.5th percentile for truncating costs. a A higher R-squared implies that the independent variables are good predictors of the variation in the dependent variable. b A higher ICC implies that profiling can reliably distinguish actual differences in performance between hospitals. We apply the selected reporting standards for the three levels of reliability (R=0.4, R=0.6, and R=0.8) to the distribution of discharges across CAHs and PPS hospitals to identify the number of hospitals of each type that fail to meet these minimum sample size standards for a given payer type and would therefore be excluded from reporting on those payer-specific costs. 4 We also identify hospitals that fail to meet the standards for each of the three payer types and 4 The distribution of attributed discharges across hospitals in Minnesota over the payer-specific measurement periods is shown in Appendix B. MEMO TO: Katie Burns, MDH FROM: Aparajita Zutshi and Eric Schone, Mathematica DATE: 6/22/2011 PAGE: 6 would therefore be excluded from peer grouping altogether. This is because hospitals would be included only as long as the hospital meets the minimum sample size standard for at least one payer type. Table 2 shows the selected standards for minimum sample sizes and their effects on the number of hospitals excluded from reporting payer-specific costs and from peer grouping altogether. 5 Table 2: Number of hospitals not meeting minimum N for all-payer and payer-specific costs Minimum N (R=0.4) Number of hospitals not meeting minimum N (R=0.4) Minimum N (R=0.6) Number of hospitals not meeting minimum N (R=0.6) Minimum N (R=0.8) Number of hospitals not meeting minimum N (R=0.8) CAHs (n=78) All-payer costs* 0 1 9 Medicare costs 15 2 33 3 89 11 Medicaid costs 11 32 24 44 64 66 Commercial costs 12 4 27 10 71 27 PPS Hospitals (n=53) All-payer costs* 1 1 1 Medicare costs 9 5 19 5 51 6 Medicaid costs 7 9 15 10 39 10 Commercial costs 16 1 37 1 99 1 Note: *The “all-payer” numbers refer to the number of hospitals that would be excluded from peer grouping altogether under each level of reliability because they lack the minimum number of discharges needed for each of the three payer types. As shown in Table 2, imposing a higher reliability standard results in higher minimum Ns and greater number of hospitals being excluded from peer grouping altogether or from reporting on a given cost measure. This is more evident for reporting of payer-specific costs than total costs because reporting of total costs only requires that a hospital satisfy the minimum N criterion for at least one payer type. For reporting of total costs, moderately high reliability (R=0.6) can be achieved by only excluding one hospital each from the group of CAHs and PPS hospitals from this reporting. Further, no additional PPS hospitals are excluded from reporting of overall costs if reliability is increased to 0.8; however, 8 additional CAHs are lost to attain this high level of reliability. For payer-specific costs, Medicaid-paid discharges in CAHs experience 5 Table 2 is produced from a comparison of minimum sample sizes between raw costs and standardized costs for the different hospital types and payer types shown in Appendix C. MEMO TO: Katie Burns, MDH FROM: Aparajita Zutshi and Eric Schone, Mathematica DATE: 6/22/2011 PAGE: 7 the greatest degree of exclusion from reporting with 44 of 78 and 66 of 78 CAHs being excluded at R=0.6 and R=0.8, respectively. E. Recommendations As a preparation for risk adjustment of hospital total care costs, we recommend addressing cost outliers by truncating them at the 99th percentile (and in a few cases the 99.5th percentile). In the process, we improved the explanatory power of the linear regression model that will be used to risk adjust costs and also improved reliability (by increasing the ICC) compared to the untransformed model. We selected recommended truncation rules for different cost types, hospital types, and payer types, by balancing the need for high explanatory power and reliability with minimum distortion in costs as measured by a reduction in the proportion of costs profiled. The recommended rules for addressing cost outliers and three options for reliability standards yielded the minimum sample of discharges to achieve those standards. Based on these minimum sample sizes, we find that we will be able to meet a high reliability standard of 0.8 and still include 98 percent of the PPS hospitals in peer grouping. To meet this high standard, however, we would end up excluding about 12 percent of the CAHs from peer grouping, but if the standard is lowered to 0.6, we would be able to include 98 percent of CAHs as well. For reporting of payer-specific costs, we can meet a moderately high level of reliability (0.6) at the cost of excluding about 10 percent of the hospitals (13 percent of CAHs and 2 percent of PPS hospitals) from reporting on commercial costs and less than 10 percent of the hospitals from reporting on Medicare costs. For discharges paid by Medicaid, however, in order to meet a reliability level of 0.6 we would end up excluding over 50 percent of CAHs and nearly 20 percent of PPS hospitals. Choosing a high level of reliability of 0.8 for reporting of payerspecific costs does not worsen exclusion for PPS hospitals but severely worsens exclusion for CAHs, particularly in the case of Medicaid costs. Because many hospitals have a small proportion of Medicaid covered stays, it is natural for them to be excluded from the ranking on Medicaid costs. However, this exclusion does not affect a hospital's overall performance as overall scores will be adjusted for payer-mix. cc: Project Team Appendix A The Effect of Truncation Rules on Explanatory Power, Reliability, and Proportion of Costs Profiled RAW COSTS Raw Commercial Costs in CAHs Rule Proportion of Costs Profiled R squared Intraclass Correlation Untransformed 0.172 0.055 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.238 0.218 0.207 0.198 0.061 0.063 0.065 0.064 91.18 95.76 97.56 98.64 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.224 0.209 0.201 0.195 0.182 0.068 0.067 0.064 0.063 0.061 93.98 96.86 98.10 98.89 99.82 R squared Intraclass Correlation Raw Medicaid Costs in CAHs Rule Proportion of Costs Profiled Untransformed 0.223 0.052 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.281 0.262 0.250 0.241 0.078 0.075 0.070 0.065 93.57 96.94 98.31 99.07 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.277 0.246 0.240 0.224 0.223 0.075 0.067 0.064 0.053 0.052 95.13 98.11 98.92 99.92 100.00 Raw Medicare Costs in CAHs Rule Proportion of Costs Profiled R squared Intraclass Correlation Untransformed 0.121 0.076 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.143 0.142 0.140 0.138 0.114 0.105 0.100 0.095 94.58 97.34 98.35 98.97 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.145 0.143 0.140 0.137 0.125 0.111 0.104 0.097 0.093 0.080 94.69 97.56 98.57 99.11 99.93 Raw Commercial Costs in PPS Hospitals Rule R squared Intraclass Correlation Proportion of Costs Profiled Untransformed 0.110 0.055 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.300 0.256 0.229 0.206 0.134 0.121 0.109 0.100 80.65 88.07 91.99 94.67 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.271 0.232 0.206 0.184 0.216 0.115 0.105 0.096 0.087 0.104 84.00 90.13 93.41 95.68 93.57 Raw Medicaid Costs in PPS Hospitals Rule R squared Intraclass Correlation Proportion of Costs Profiled Untransformed 0.118 0.057 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.257 0.233 0.216 0.196 0.193 0.132 0.110 0.092 83.98 90.47 93.53 96.00 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.242 0.211 0.195 0.178 0.183 0.114 0.096 0.088 0.080 0.082 86.89 92.71 95.16 96.97 97.25 Raw Medicare Costs in PPS Hospitals Rule R squared Intraclass Correlation Proportion of Costs Profiled Untransformed 0.122 0.056 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.162 0.155 0.152 0.150 0.116 0.101 0.093 0.086 91.44 95.36 96.97 97.92 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.153 0.151 0.149 0.145 0.143 0.100 0.093 0.087 0.079 0.073 92.40 95.66 97.07 98.18 99.05 STANDARDIZED COSTS Standardized Commercial Costs in CAHs R squared Intraclass Correlation Proportion of Costs Profiled Untransformed 0.124 0.039 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.298 0.268 0.249 0.223 0.054 0.055 0.053 0.047 88.60 92.40 94.13 95.84 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.266 0.220 0.193 0.169 0.179 0.049 0.042 0.041 0.036 0.042 90.77 94.17 95.95 97.53 97.92 R squared Intraclass Correlation Proportion of Costs Profiled Untransformed 0.240 0.041 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.319 0.297 0.283 0.270 0.067 0.063 0.059 0.054 93.54 96.44 97.94 98.87 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.289 0.265 0.249 0.243 0.240 0.050 0.045 0.050 0.046 0.041 95.71 98.19 99.30 99.75 100.00 R squared Intraclass Correlation Proportion of Costs Profiled Untransformed 0.133 0.036 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.169 0.161 0.156 0.151 0.041 0.043 0.043 0.043 95.00 97.67 98.65 99.15 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.164 0.158 0.154 0.150 0.133 0.047 0.046 0.044 0.043 0.036 95.46 97.81 98.72 99.22 100.00 Rule Standardized Medicaid Costs in CAHs Rule Standardized Medicare Costs in CAHs Rule Standardized Commercial Costs in PPS Hospitals Rule R squared Intraclass Correlation Proportion of Costs Profiled Untransformed 0.154 0.034 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.334 0.299 0.275 0.252 0.045 0.041 0.039 0.039 86.48 92.11 94.80 96.66 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.305 0.275 0.254 0.236 0.246 0.036 0.037 0.038 0.039 0.039 89.09 93.59 95.75 97.22 97.04 Intraclass Correlation Proportion of Costs Profiled Standardized Medicaid Costs in PPS Hospitals Rule R squared Untransformed 0.146 0.036 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.265 0.241 0.223 0.207 0.147 0.194 0.196 0.167 84.93 91.81 94.68 96.68 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.244 0.226 0.207 0.188 0.192 0.219 0.234 0.195 0.130 0.137 87.10 92.94 95.88 97.78 97.97 Intraclass Correlation Proportion of Costs Profiled Standardized Medicare Costs in PPS Hospitals Rule R squared Untransformed 0.137 0.050 100.00 Global percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile 0.161 0.161 0.159 0.156 0.085 0.078 0.072 0.067 91.99 95.96 97.58 98.55 MDC specific percentiles 95th Percentile 98th Percentile 99th Percentile 99.5th Percentile $100,000 0.157 0.158 0.156 0.153 0.150 0.076 0.073 0.068 0.064 0.058 92.66 96.35 97.84 98.76 99.52 Appendix B Distribution of Attributed Hospital Admissions in Minnesota Distribution of Attributed Admissions in Minnesota (January 2008 - December 2008 for Medicare and July 2008 - June 2009 for Other Payers) Number Number of of hospitals discharges Percentile Mean 10th 25th 50th 75th 681 315 43 316 CAHs Medicare Medicaid Commercial 78 78 78 78 37,731 18953 2,596 16,182 484 243 33 208 108 69 0 20 206 128 2 45 340 201 18 112 PPS Hospitals Medicare Medicaid Commercial 53 53 53 53 350,703 119,662 38,306 192,735 6,617 2,258 723 3,637 1,493 33 0 716 2,046 718 183 914 3,330 1,320 298 1,896 All Hospitals Medicare Medicaid Commercial 131 131 131 131 388,434 138,615 40,902 208,917 2,965 1,058 312 1,595 139 69 0 31 300 140 4 89 814 315 38 390 90th 1,127 451 114 515 10,051 3,150 924 5,178 16,691 6,388 2,083 9,731 2,770 946 251 1,363 10,051 3,150 924 5,178 Appendix C Number of CAHs and PPS Hospitals not Meeting Minimum Sample Sizes for Raw Costs and Standardized Costs for each Payer Type and for all Payer Types Number of hospitals not meeting minimum N for each payer type and overall Minimum N (R=0.4) Number of hospitals not meeting minimum N (R=0.4) Minimum N (R=0.6) Number of hospitals not meeting minimum N (R=0.6) Minimum N (R=0.8) Number of hospitals not meeting minimum N (R=0.8) Raw Costs CAHs Total 0 0 2 Medicare 6 2 14 2 36 4 Medicaid 9 29 20 43 53 61 10 3 22 8 58 21 Commercial PPS Hospitals Total 1 1 1 Medicare 7 5 15 5 39 6 Medicaid 7 9 15 10 39 10 Commercial 6 1 14 1 36 1 Standardized Costs CAHs Total 0 1 9 Medicare 15 2 33 3 89 11 Medicaid 11 32 24 44 64 66 Commercial 12 4 27 10 71 27 PPS Hospitals Total 1 1 1 Medicare 9 5 19 5 51 6 Medicaid 3 8 6 9 16 10 16 1 37 1 99 1 Commercial
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