Obviously, we here at DocGraph want to see more and more doctor data released. So we should admit that bias to start.
We also care about what other people think, so we were very excited to see the release of the comments regarding the change of policy regarding the release of doctor-identified patient-blinded claims data. In many cases it is hard to understand how policy makers are thinking into you see how the public is reacting to their decisions. With that in mind, I arm-twisted by sister, Alma, into doing some data analysis on the comments themselves. I wanted to understand what kind of patterns the comments showed. I was expecting, for instance, that organizations that represented patients would comment very different typically than organizations representing doctors.
Alma read every comment, and answered specific questions about each comment in a spreadsheet that we plan to release soon. She also summarized the comments as she went along, and she did such a fine job with that summary that I thought the DocGraph community might be interested in her analysis. Here it is in its entirety:
Regarding the release more doctor data by CMS
The form and direction of the data release was a frequently covered topic. Raw, disaggregate line-item data, aggregated data, or both? Into the hands of the public, or first to an intermediary such as a Qualified Entity, stakeholder or other approved party? Limited to internal or public uses?
A large portion of respondents (frequently, but certainly not limited to, providers) believe the data should be aggregated initially, or that raw data should be presented only to entities with appropriate security safeguards and mechanisms to analyze the data and prevent misinterpretation. The misinterpretation factor was brought up time and again, by different types of responders. The public could easily misread the information and make faulty assumptions about certain doctors, providers and procedures, ultimately taking a step backward from the goal of better care.
While the method of release was highly contested, there was a general agreement that timely updates of the data are key to making it useful. Some frustration expressed with CMS’ past performance in this regard.
Many journalists and open data proponents/analysts think releasing data to the public, or by relaxing the prerequisites and ensuring affordability in obtaining the data, could prevent backlog or delay from information requests and allow for faster analysis. Providing developers and interested parties access to line-item, disaggregate data could also expedite the flow and achieve more meaningful results. Aggregating the data before its release could not only delay its availability, but most importantly constrain the results and insights of future data processing.
Both providers and non-providers suggested an expansion on the QE program to allow a greater number of (experienced and trustworthy) hands access to the data. See pg 209 and 178 for more about that idea.
Most anxiety came from providers, primarily that physician identity and privacy may be at risk and that the data will almost certainly be misinterpreted if released raw to the public. Generally providers desired CMS or a party with proven skills to to aggregate or remove physician identifiable information, such as their NPI, before released to the public. Their major reason being that the public will misconstrue the payments to physicians and make poor health care decisions.The public will simply see a physician’s payment data, without understanding factors such as team-based care, overhead and operational costs, how services are billed, geography, patient load, specialized services, etc. They hope to constantly review their information to check for accuracy, and attach comments and explanations.
Some (mostly non-provider) groups believed that physician privacy was not an issue, as physicians are business entities, making transactions with the government. Their privacy, by law, is not an issue. Others were certain that the precautions taken by CMS, or by approved data handlers, to protect physician (and patient) privacy will be quite sufficient.
Patient privacy was also a major concern from providers (though obviously not as great as physician privacy), with fears that the patients could be identified through rare, costly, or unusual procedures.
Still, I got the impression that providers believe the move to release this data is inevitable (and perhaps beneficial in the long term), so they addressed the most important risks with hope that the release could improve healthcare more than hurt it. Desire that CMS will work with them in developing the policies for this release, and monitor the results from data analyses.
Most everyone believed that a great benefit will arise by combining the Medicare data with other types of payment data, to get a broader sense of how physicians are performing. Also that the public will need encouragement and aid to actually use this information and understand it in a clear and meaningful way.
The administrative burdens, misdirected audits/misuse suspicion arising from this information were a concern from providers. Especially that this will lead to doctors no longer accepting Medicare patients. However, many groups of all kinds believed that with the proper context in place, prevention of fraud and waste could be possible.
Regarding the comments made by Individuals rather than groups:
Lots of regular joe’s are ready to pounce on data.. Many disgruntled folks who want to know where their tax dollars are going and/or those who feel blind in the healthcare system where they are frequently gouged. Again, believe that if someone is doing business with the government, they lose their right to privacy.
However, some joe’s think this will only lead to more bureaucratic nonsense. Waste of time and efforts, that will make lawsuits more frequent and invade physician privacy. Might as well release individual’s tax payments towards Medicare publicly as well. America!
Individual doctors more vehement and caustic about releasing their data than their above representatives (though some are eager to see change and progress through data availability). Some threatened to drop Medicare patients to avoid the hassle. Mentions that a greater class divide will result, and loads feel that their privacy will greatly violated.