Protecting, maintaining and improving the health of all Minnesotans Date: June 1, 2011 To: Provider Peer Grouping Rapid Response Team members From: Katie Burns, Health Economics Program Subject: Tools for Clinic-Level Peer Grouping Thank you for participating in the Rapid Response Team. In preparation for our next meeting, I wanted to distribute the attached memo. The memo describes tools we are using to conduct the PPG physician clinic analysis at a clinic level. Specifically, it describes a measure called the Primary Care Service Index (PCSI) and outlines how MDH will use the PCSI and its components to facilitate a clinic level of analysis. We are also proposing to use the PCSI to perform a service mix adjustment and are soliciting RRT input on whether a need exists for a separate adjustment to account for variations in service mix or whether the ACG risk adjustment tool can adequately account for this type of variation to the extent such adjustment is warranted. We will review the memo during our meeting to ensure you have an opportunity to clarify your understanding of the issues and to ask questions. Response deadline: We will need your feedback on these issues by Tuesday, June 14 at 4:00 pm. Responses may be provided via email to [email protected]. Memo Date: May 31, 2011 To: Provider Peer Grouping Rapid Response Team From: Kevan Edwards Katie Burns Subject: Tools for Peer Grouping at a Clinic Level Introduction Provider peer grouping (PPG) compares providers on a combined measure of risk-adjusted cost and quality for a provider’s total patient population as well as for select specific health conditions. Consistent with the Provider Peer Grouping Advisory Group’s recommendations, clinics that offer primary care will be included in total care PPG while both primary care and relevant specialty-only clinics will be included in the condition-specific analysis. Based on our work to date, MDH intends to peer group at the clinic level, rather than at the medical group level, in the first iteration of PPG. The purpose of this memo is to describe several key aspects of the total care physician clinic analysis, particularly in the context of clinic-level peer grouping. First, this memo describes our method for linking individual providers to clinic locations and allocating their time across multiple clinics when necessary. Second, this memo describes our method for assessing the extent to which primary care is practiced at an individual clinic and how this information could be used to perform a service mix adjustment. MDH is soliciting RRT input on whether a need exists for a separate adjustment to account for variations in service mix or whether the ACG risk adjustment tool can adequately account for this type of variation to the extent such adjustment is warranted. Specifically, MDH has developed a measure – the Primary Care Service Index or PCSI – as a useful tool for assessing the extent to which clinical staff at particular physician clinics practice primary care. MDH will use the PCSI score and the availability of sufficient quality measures for the quality composite as described in a previous memo for determining whether a clinic should be included in total care PPG. MDH will also use a component of the PCSI -- information from the state licensing file about clinic priority locations – to allocate costs for a single provider across the various clinics at which s/he is registered for those providers registered at multiple clinics. MDH is also considering using the PCSI measure to adjust costs as a final step in the physician clinic analysis in order to more fairly compare clinics offering different types of services. Division of Health Policy/ Health Economics Program • 85 East Seventh Place • Suite 220 • St. Paul, MN 55101 www.health.state.mn.us Linking Physicians and Clinical Staff to Clinic Locations Claims data links patients with individual providers; it does not associate patients with specific clinic locations. To associate individual providers with specific clinics, providers have been linked to clinics through information in the Minnesota Statewide Quality Reporting and Measurement System physician clinic registry. Patient costs have been attributed to individual providers consistent with the multiple proportional rule we discussed in a previous memo and the linkage between providers and clinics has been used to attribute patient costs to clinics. Approximately 24% of providers are linked with multiple sites in the physician clinic registry. Patient costs attributed to providers registered with multiple physician clinics will be allocated across the multiple clinics using weights based on the best information available as described later in this memo. Physician clinics are required to annually register all clinical staff at a clinic site level, providing the clinic’s name and clinic-level National Provider Identification (NPI) number as well as names and individual-level NPIs for each clinical staff (physicians, physician assistants, and advanced practice registered nurses). The registry that will be used in the first iteration of PPG was populated in early 2010 based on data related to 2009 dates of service, the same service dates that will be used in the physician clinic analysis. Physician clinics completed the registry with varying levels of care. MDH has invested a significant amount of time in verifying and cleaning fields in the registry. MDH used the data sources described below to assist in this process. Data Sources Three sources of data were used to link providers to specific physician clinics, to determine how to allocate costs across clinics for providers affiliated with multiple clinics, and to develop the measure that assesses the extent to which primary care is practiced at a particular physician clinic. These include the National Plan and Provider Enumeration System (NPPES) registration file, the Minnesota Statewide Quality Reporting and Measurement System physician clinic registry, and the Minnesota Board of Medical Practice licensure file. In combination, these three sources of data provide the following key pieces of information: 1. An individual provider’s practice location(s), 2. An individual provider’s NPI number and self-selected taxonomy codes (up to four) which indicate the types of care the provider practices, 3. An individual provider’s priority rating for each type of care (i.e., the principal form of care provided or a secondary form of care), and 4. A physician’s priority rating of the clinic practice location (i.e., principal place of practice or a secondary place of practice). Together, these data elements allow MDH to link individual clinic staff (including physicians, advanced practice registered nurses, and physician assistants) to particular clinic locations, and approximate how physicians allocate their time across each physician clinic at which they are registered. These data are also used to assess the combination of verified physician specialties at -2- each physician clinic to create a measure of the extent to which individual physicians and other clinical staff practice primary care as well as the extent to which a clinic location provides primary care. Prior to demonstrating the calculation of the primary care service index, it is useful to pause and explain the role of each data element in the overall measure. Practice Location: In the Minnesota Statewide Quality Reporting and Measurement System physician clinic registry, physicians may be registered at up to three clinic locations. Of the 15,312 clinical staff included in the 2010 physician clinic registry, 3,650 (24 percent) of providers are registered at multiple locations. In order to properly gauge the primary care capacity of each clinic, it is necessary to calculate a unique primary care capacity measure for each clinical staff at each clinic location at which he/she is registered in order to account for how a particular provider contributes to an overall measure of primary care capacity at a specific clinic. Taxonomy Codes: Taxonomy codes are a classification system which describes specializations and sub-specialties of medical care. For purposes of PPG, MDH consulted with medical organizations and designated the following specialties as primary care providers (a more detailed list of which specialties are considered primary care is presented in Attachment A): 1. 2. 3. 4. 5. Family Health and Primary Care specialties Selected Internal Medicine specialties All Gerontologists Selected OB/GYN specialties Selected Pediatrician specialties Taxonomy code values which fall into these categories of “primary care” are assigned a primary care value of one. All other taxonomy codes values outside the range of primary care are assigned a primary care value of zero. Medical Specialty and Taxonomy Priority Rating (TPR): Each reported taxonomy code is rated by priority in the taxonomy history of the provider. The assigned weight depends on the number of taxonomy codes reported and the provider’s rating of each taxonomy code as either their principal or secondary medical specialty. For example: -3- Table 1: Examples of Weighting Associated with Taxonomy Priority Weighting Number of Taxonomy Codes One Two Two Three Three Priority Assigned to Taxonomy Codes? Not necessary Yes No Yes No TPR of second TPR of first 1 Taxonomy Code Taxonomy Code TPR of third Taxonomy Code 1 .7 .5 .6 .333 N/A N/A N/A .2 .333 N/A .3 .5 .2 .333 Clinic Location and Clinic Priority Rating (CPR): In the physician clinic registry, clinical staff may be registered at up to three clinic locations. For some of the 24% of clinical staff who practice at multiple locations, the state licensure file provides information about how physicians allocate their time across various practice locations. In such cases, one clinic is designated as the principal practice location while the other clinic(s) are deemed as secondary practice locations. Based on the number of clinics at which the physician practices, and the priority ranking of each clinic, weights can be assigned to that clinic to approximate the involvement of that physician in the care of the clinic’s patients. The essential concept behind the weights is that they sum to 1.0 to approximate the distribution of a full time employee over all clinics at which they are registered. While these weights are approximations, they have the benefit of allowing us to approximate the extent to which a physician or other clinical staff practice at particular clinic locations. These weights will be used to allocate costs among clinics for providers who are registered at multiple clinics. The weights are described in Table 2 below: Table 2: Weighting Associated with Clinic “Priority Ratings” 2 Number of Clinics at Which a Physician is Registered One Two Two Three Three Is One Clinic Noted as the Priority Location? CPR for physician’s first clinic location CPR for physician’s second clinic location CPR for physician’s third clinic location Sum of Physician’s CPR scores Not necessary Yes No Yes No 1.0 .7 .5 .6 .333 N/A .3 .5 .2 .333 N/A N/A N/A .2 .333 1.0 1.0 1.0 1.0 1.0 1 Considered the primary taxonomy code when a priority among multiple taxonomy codes is indicated. Costs will be allocated across physician clinics for those providers registered at multiple clinics based on these weights. 2 -4- Calculation of the Individual Primary Care Service Index Value An individual provider’s primary care service index value is calculated using the following formula: ( PCVi j *TPRi j *CPR) Where: PCV= Primary Care Value TPR= Taxonomy Priority Rating CPR= Clinic Priority Rating i = first taxonomy code j = last taxonomy code It is important to note that an individual provider receives an individual PCSI value for each clinic at which they are registered. Our intention is to aggregate the individual PCSI scores at a clinic to the clinic level. Table 3 provides an example of the data inputs and resulting individual primary care scores for three separate hypothetical physicians. Table 3: Individual Primary Care Service Index Values for Three Physicians Provider Data Element Taxonomy Code 1 Taxonomy Code 2 Taxonomy Code 3 Taxonomy Code 4 Taxonomy 1 Priority Taxonomy 2 Priority Taxonomy 3 Priority Taxonomy 4 Priority Clinic Priority Individual Prim ary Care Score Dr. Davis Description Primary Care NA NA NA Principal NA NA NA Principal (1/1) Dr. Rogers Value / Rating 1 1 1 Description Primary Care Specialty NA NA Principal Secondary NA NA Principal (1/1) 1 0.7 Dr. Thompson Value / Rating 1 0 0.7 0.3 1 Description Specialist Primary Care Primary Care NA Principal Secondary Secondary NA Principal (1/2) Value / Rating 0 1 1 0.6 0.2 0.2 0.7 0.28 To further illustrate the calculation, look at the individual primary care score for Dr. Thompson. Dr. Thompson has three taxonomy codes, two of which are considered primary care. Dr. Thompson’s principal practice involves a specialty outside of primary care and so the specialty priority is assigned a priority weight of 0.6. The two primary care service categories share the remaining 0.4 of the practice priority weight and are each assigned a value of 0.2. Finally, Dr. -5- Thompson practices at two clinic locations. This clinic is his/her main location and thus the clinic priority rating is assigned a value of 0.7. Using Dr. Thompson as an example, to calculate his/her individual PCSI at this clinic using the PCSI formula described previously, we do the following: PCSI i = (0 * 0.6 * 07) + (1 * 0.2 * 0.7) + (1 * 0.2 * 0.7) = (0) + (.14) + (.14) = 0.28 Calculation of Clinic Level PCSI Values The PCSI value for the clinic is easily calculated from knowing the staff clinic priority values and the individual level provider PCSI scores. The formula is: (PCSI i ) PCSI c (CPRi ) Where: PCSI c = Clinic level PCSI value PCSI i = Individual provider PCSI value CPR i = Individual provider Clinic Priority Rating In the hypothetical three physician clinic used previously, the sum of the individual level PCSI scores is: PCSI i = 1 + 0.7 + 0.28 = 1.98 The sum of the individual provider clinic priority ratings serves as a proxy measure of the FTEs for the providers registered at that clinic. In the example the sum of the clinic priority ratings is: CPRi = 1 + 1 + 0.7 = 2.7 Using the formula for clinic level PCSI, the PCSI value for this clinic is: PCSI c = 1.98 / 2.7 = 0.73 -6- Planned and Potential Uses of the PCSI Measure The physician clinic total care analysis will only include clinics offering primary care. The PCSI values can be used to help determine whether a particular clinic is likely to offer sufficient levels of primary care to be comparable to other clinics in the PPG total care analysis. By looking at the distribution of clinic level PCSI scores, there is a clear bi-modal distribution pattern among Minnesota physician clinics. Figure 1: Distribution of Clinic Level PCSI Values Clinics with a PCSI value of zero are specialty-only clinics. These clinics have no registered clinical staff who report taxonomy codes that fit the definition of primary care. In addition to the clinics with PCSI values equal to zero, those clinics with PCSI scores less than 0.30 have proportionally few clinical staff at that location who report having a primary care specialty. MDH believes the PSCI measure is a reasonable approximation of the extent to which primary care is practiced at specific clinics. MDH analyzed clinic PCSI scores and notes that as PCSI scores increase from zero to one, an increasing amount of data is available on quality measures applicable to primary care providers across a range of quality measures. More specifically, an analysis of clinics with PCSI values of less than 0.30 showed that most of these clinics either did not submit quality measures required of primary care provider specialties or have organizational descriptors that indicate the clinic is a specific specialty care provider. Based on this information and a policy goal of including only clinics that offer primary care, we have decided to only include clinics with a PCSI score higher than 0.30 and who meet the criteria -7- related to the construction of the composite quality measure (i.e. have sufficient data for at least one measure in each subcomposite category). This will help ensure the clinics included in PPG total care provide at least a minimal threshold of primary care. Once we have applied this criteria, the average PCSI score of remaining clinics increases from a statewide average of .59 to .83. The accuracy of the PCSI relies on providers accurately reporting taxonomy codes and their priority in national NPI registry files, accurate registration of providers at clinics, and accurate information about clinic priority in the state licensure file. We encourage continued efforts to maximize accurate data submissions and reporting in these data sources. Potential Use of the PCSI to Adjust Costs At the Clinic Level MDH is also proposing to use the clinic PCSI score to adjust costs between clinics with different primary care capacity to account for cost variation attributable to differences in the services provided. The proposed service mix adjustment uses a ratio approach, weighting the clinic’s attributed risk adjusted cost of care by the ratio of the clinic specific PSCI to the state wide average PCSI. Further, the proposed service mix adjuster would occur as the last step in the adjustment process, taking place only after all other forms of risk adjustment (related to clinical/diagnostic differences, payer mix, and outliers) have been performed Table 4 provides an example of the proposed service mix adjuster using three separate hypothetical clinics. Table 4: Service Mix Adjustment Example Clinic Attributed Risk-Adjusted Patients Attributed Costs Clinic PCSI Score Risk-Adjusted Per Patient Per Year Total Cost of Care Dollars Relative Cost Weight Service Mix Adjusted Per Patient Per Year Total Cost of Care Dollars Relative Cost Weight A 250 $230,560.00 0.7315 $922.24 0.79 $816.33 0.70 B 1,000 $654,540.00 0.9865 $654.54 0.56 $781.35 0.67 C 350 $545,690.00 0.6845 $1,559.11 1.33 $1,291.40 1.10 4,250,600 $4,973,202,000 0.8264 $1,170.00 1.00 $1,170.00 1.00 State Wide Values Using Clinic A from Table 4 as an example, the annual per patient total cost of care is determined by dividing the total attributed costs at the clinic by the total attributed patients at the clinic. For Clinic A, this is equal to $230,560 / 250 or $922.24 per patient per year. -8- Prior to adjustment for service mix, clinics can be compared to other clinics in the state by dividing clinic specific risk-adjusted annual per patient costs by the statewide average annual per patient cost. For Clinic A this is equal to $922.24 / $1170 or 0.79 (79% of the statewide average per patient annual cost). However, to improve the comparison for clinics with differing service mix, the annual per patient total cost of care can be adjusted to reflect the clinic’s staff capacity for primary care relative to the statewide average primary care capacity. Clinic A’s PCSI value is 0.7315, a little less than the statewide benchmark for all clinics of 0.8264. To adjust costs to reflect the service mix difference, multiply the unadjusted annual per patient costs by the Clinic PCSI to Statewide PCSI ratio. For clinic A this is equal to $922.24 * (0.7315 / 0.8264) = $816.33. Clinic A’s PCSI service mix adjusted costs can be compared to other clinic’s service mix adjusted costs by dividing the clinic specific annual per patient cost by the statewide average annual per patient cost (note the value is the same adjusted or unadjusted by service mix). The adjusted comparison is equal to $816.33 / $1,170 or 0.70 (70% of the statewide average per patient annual cost). Conclusions: MDH developed the PCSI as a unique measure of the extent to which primary care is practiced at particular clinics. Because total care PPG is intended to include comparable clinics offering primary care and because clinics differ in the extent to which they offer primary care, MDH will use the PCSI as one criterion for determining whether clinics are included in the PPG total care analysis. MDH will also use a component of the PCSI -- information from the state licensing file about clinic priority locations – to allocate costs for a single provider across the various clinics at which s/he is registered for those providers registered at multiple clinics. MDH is proposing to use the PCSI measure to adjust costs between primary care only clinics and multispecialty clinics that offer primary care as outlined above, used on the heels of clinical/diagnostic, outlier, and payer mix risk adjustments. MDH is soliciting feedback on whether an adjustment related to service mix is needed in the context of clinic-level peer grouping. MDH appreciates that some aspects of differences in service mix will be accounted for through the use of ACGs as more severely ill patients are likely to receive care from specialists. MDH is seeking stakeholder feedback about whether the ACG-based risk adjustment method sufficiently accounts for differences in service mix or whether additional adjustment based on PCSI values is warranted. -9-
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