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MHTC Letter to MA Division of Health Care Finance and Policy on Data Transparency Regulations

March 20, 2006

Ms. Amy Lischko, Commissioner
Massachusetts Division of Health Care Finance and Policy
Commonwealth of Massachusetts
Two Boylston Street
Boston, MA 02116

Dear Commissioner Lischko:

On behalf of the Massachusetts High Technology Council, which represents CEOs from the state’s top technology employers, I appreciate the opportunity to comment on the Division of Health Care Finance and Policy’s (DHCFP) proposed changes to 114.5 CMR 2.00, Disclosure of Hospital Case Mix and Charge Data. The Council strongly supports implementation of DHCPF’s recommendation to include the Board of Registration physician license number as part of the public disclosed data.

The Council has been a strong proponent of measures to promote greater transparency around the cost and quality of patient care. For the health care system to function properly, accurate information about quality, pricing, supply and alternative care sites must be publicly available. In fact, developing a better system for transparency was the Council’s top priority in the ongoing health care reform debate.

The state's Health Care Quality and Cost Information website has been an important resource in lifting the veil on the state’s health care system, but more data is needed to help consumers understand cost and quality differences throughout the system – including for major health care payors like our member companies. Adding the physician license number can ultimately help to make cost and quality outcomes more transparent to consumers, thereby allowing them to make more informed health care choices.

Not only would this measure hold providers more accountable and help foster increased competition in the marketplace, adding the physician license number will provide a mechanism so that cost and quality information on individual physicians is gathered and aggregated in a consistent and impartial manner. And it is also critical to signal that the information on physicians comes from a reliable and independent source.

Consumers' choices will only be as good as the quality of information available to them. Having accurate cost and quality data available will help to support new, lower premium products that seek to change consumers' behavior by encouraging individuals to utilize lower cost and better value settings.

We believe that DHCFP should move ahead with the proposed regulations and that the Council be included in any consultative group that will be examining the issue so that the payor's voice is heard on this issue.

Sincerely,

Christopher R. Anderson
President