OCA staff seek feedback on data‑submission guide and options for defining a hospital sector target

OCA staff presented a revised data submission guide and timeline for 2025 data collection, and asked the advisory committee for input on defining a hospital sector and setting sector targets. Staff said draft regulations and the updated data submission guide were posted Jan. 8 and public comments are due Jan. 31; required submitters are expected to register in May and submit 2023–24 files by Sept. 1, 2025. Staff also described the measurement modules that will collect claims and non‑claims primary‑care and alternative‑payment model (APM) data, and reiterated the office’s plan to publish a second baseline report by June 1, 2026.

On sector definition, staff outlined four options for addressing high‑cost hospitals: (1) wait and defer sector target setting until 2027; (2) narrowly define a sector for three Monterey hospitals (as requested publicly) and set a target for them; (3) define a high‑cost hospital sector using facility attributes and financial thresholds; or (4) define “all hospitals” as a sector and allow the Board to adjust targets for selected hospitals (the staff recommendation if the Board wants sector targets effective for performance year 2026). Staff explained differences in how hospitals report to HCAI — Kaiser hospitals may submit consolidated statements by region — and noted that some hospitals can file limited data due to statutory or operational exemptions (state hospitals, county psychiatric health facilities, Shriners and long‑term‑stay hospitals).

Committee members raised multiple technical questions and concerns: how to measure outpatient activity (staff said current HCAI financial reporting lacks outpatient case weights and the office is exploring ways to incorporate outpatient intensity), how to handle small hospitals and volatility in multi‑year averages, and how to treat overlapping categories (teaching hospitals that also are children’s hospitals or part of integrated systems). Members urged the office to publish the underlying data spreadsheets, to show how exclusions change lists of high‑cost hospitals, and to consider sector‑level target options (e.g., academic medical centers, psychiatric hospitals, critical access) rather than ad hoc single‑hospital exceptions. Several committee members supported option 4 (define hospitals as a sector and allow targeted adjustments) because it preserves flexibility and can be implemented in time for 2026 targets; others urged caution and recommended waiting for better outpatient measurement and HPD data.

Staff said they will return with implementation details and options for target values; the Board will vote on any sector definitions and target values in the coming months and staff will proceed with data‑collection steps for the 2025 cycle whether or not the Board finalizes a hospital sector.