Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
State Medical Facilities Plan [12 VAC 5 ‑ 230]
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6/13/17  10:16 am
Commenter: Michael Ellwood


The goal of both health policy and health care is to provide quality care to the patient. That is well-described in the six domains put forth by the IOM: Safe, Effective, Patient-centered, Timely, Efficient and Equitable. The current health care system (which includes the current SMFP) sometimes fails to meet those goals. However, how would modification achieve it better? Virginia already experiences an imbalance of over accessibility and over utilization in some areas and inaccessibility in others. Additional healthcare facilities in an area routinely demonstrate an increase in utilization and cost without correlating improvements in quality. Also, clinical and information technology is allowing healthcare to become more virtual and patient-centered - the right care and the right time with less need for facilities.

With 25 years in healthcare quality measurement and policy, I am a strong advocate of public reporting of quality as a means for health care organizations to be accountable to the public. Health care organizations strive even harder for quality when there performance is public. If the SMFP were modified, it should be done with a requirement that the facilities report nationally endorsed quality and safety metrics. These quality metrics should be available at the facility level, include outcomes measures (not just process measures), be current, be available from the main web page of the organization, and be provided to the public upon request (phone and electronic message). In addition, the amount of charity care in terms of numbers of patients by age range should be as publicly accessible as the quality and safety metrics.

Health care delivery is changing continually. It is difficult for the SMFP to anticipate the needs for health care facilities into the future. It is not hard to imagine innovative health organization might improve upon the plan. However, health care organizations should be held publicly accountable through publicly available quality, safety and charity care reporting. There are few, if any, health care organizations in Virginia that publicly provide current outcomes measures for the care they provide.

CommentID: 60247