Public Comments - Bureau of Primary Health Care (BPHC)

General Comments

American Optometric Association, Alexandria, VA

We welcome efforts to identify and minimize regulatory burden across the health care sector, including burdens on health centers. The Uniform Data System (UDS) has provided useful information as we consider the future optometric workforce needs and possible future employment settings. The almost 25 percent increase in the number of health centers offering vision services between 2014 and 2016, demonstrated by UDS, makes clear that health centers are increasingly aware of the value of eye care for their patients and the important role eye care providers can play in the interdisciplinary health center setting.

Therefore, while we support attempts to simplify the process by which health centers input data into the system, we also encourage the BPHC to exercise caution as it streamlines the reportable data. Information regarding vision care, traditionally an underserved area in health centers, is vital to evaluating and responding to the needs of the patient population in underserved communities.

OCHIN, Portland, OR

  1. While OCHIN supports the Performance Data Collection Environment (PDCE) in principle, we advocate for direct EHR-reporting to further reduce administrative burden for health centers. OCHIN supports moving toward direct EHR-reporting where appropriate, and urges BPHC to align with existing quality reporting programs that allow/require direct EHR-reporting and ensure a process exists that health centers can meet. OCHIN has experience with direct EHR-reporting and hopes BPHC builds a program that acknowledges the limitations with direct EHR-reporting.
  2. OCHIN also recommends aligning MU and MIPS to the same measures. This would allow for a single report to be submitted which meets the requirements of both, creating an alignment of electronic submissions. State and federal coordination will help reduce duplication, provider burnout and administrative complexity. Additionally, OCHIN believes HRSA could incentivize organizations to meet the goals on a regular basis by including a monthly reporting option. This would improve the organization’s operations as opposed to collecting less meaningful annual data that result in greater provider complexity.
  3. Extracting patient data based on countable clinical visits is likely feasible. OCHIN supports reducing redundancy of data submission, acknowledging that direct-EHR reporting may accomplish this.

RFI section A.1

AIDS United, Washington, DC (Legacy Community Health)

Legacy supports HRSA's suggestion to open the Uniform Data System (UDS) reporting process earlier than January 1st and allow data to be entered from September 1-December 31. This change will allow health centers more time to accurately complete UDS data and ensure data is validated in a timely manner.

ALTURA Centers for Health, Tulare, CA

Because the UDS is comprised of data from the calendar year, it does not help us to begin populating the data earlier than January 31st, because none of the UDS data is complete before January. The NextGen electronic health record system reports much of the UDS data by billed encounters; it takes several weeks for providers to close out their December encounters and have the billing department submit billing, for the encounters to be counted in the UDS report. Also, because there is a huge amount of information needed to report on the UDS, it would be extremely helpful if the due date could be extended to March 31. That would give us the month of January to ensure that all the previous year encounters have been processed, and then give us the months of February and March to extract and validate data, work on any technical reporting issues with NextGen, enter into the EHB, respond to any UDS Validation Questions, and submit the report by March 31st.

Bi-State Primary Care Association, Montpelier, VT

Bi-State and the VT and NH FQHCs agree that early access to the UDS reporting module might be useful; however they note that health centers will still need to wait for the year to end to finalize uploads and tallies. Some health centers will no doubt appreciate the longer lead time. While this may not reduce overall burden, additional flexibility is always appreciated.

Bristol Bay Area Health Corporation, Dillingham, AK

Support for giving more time (from September 1 to December 31) prior to start of official reporting period to being report population and validation. It should be noted that our EHR relies on a UDS "patch" from Indian Health Services (IHS) for UDS data extraction. Unless IHS advances the UDS "patch" to our organization one quarter in advance, this proposed change will not positively impact our specific organization.

California Primary Care Association (CPCA), Sacramento, CA

It would be very helpful to have more time to populate UDS. However, because some UDS elements are not quantifiable until the close of the calendar year, providing an extended time to report post-January 1, would be more helpful than the Bureau's current proposal to allow health centers to populate earlier in the year. CPCA recommends an extended UDS reporting time frame, but the extension should be an extension of the deadline, opening January 1, and closing March 15 or later.

Chicago Family Health Center, Chicago, IL

This would not have a significant impact on submission of the UDS. Since all of the data must be calendar year, health centers would be unable to do much work prior to January 1. While we welcome the option for the system to open earlier, an additional two weeks to submit data would be preferred to reduce administrative burden.

Community Clinic Association of Los Angeles County (CCALAC), Los Angeles, CA

While it would be helpful to have more time to populate UDS, some elements are not quantifiable until the close of the calendar year. As such, providing an extended time period to report post-January 1 would be more helpful than the proposal to allow health centers to populate their UDS data earlier than January 1.

CCALAC supports an extended UDS reporting time frame, but recommends an extension of the deadline, opening January 1 and closing March 15 or later, as opposed to an option to begin populating early.

Community Health Systems, Inc., Moreno Valley, CA

Yes, health centers should be able to start gathering data early to avoid inaccuracies and having tables returned for errors.

Eastern Aleutian Tribes, Anchorage, AK

We support the idea to be able to access the UDS data-reporting environment as early as September 1st, so we can populate our UDS reports and perform validation on data entered to ensure accuracy and integrity.

Family Health Centers of San Diego, San Diego, CA

While Family Health Centers of San Diego would likely not use this feature as we have an internal system already used to secure data accuracy and integrity, we realize we are in a unique position having developed our own EHR. We feel the feature could be beneficial to other FQHCs and support the PDCE with the caveat that data can, but does not necessarily automatically export into the UDS live data reporting environment. Additionally, we feel that much of the "back and forth between health centers and UDS data reviewers" referred to in the RFI, is the result of the UDS reporting system being under the sole control of one person with both editing and supervisory roles. One person should not have the ability to arbitrarily edit the UDS manual and also have supervisory role over the UDS manual edits that may result in centers underreporting UDS data elements such as patient encounter data with no possible formal appeal process to protest the edits to a supervisor as a single individual serves both roles. This prohibits a health center from having an impartial third party to review and adjudicate center's UDS data.

Health Center Partners of Southern California, San Diego, CA

Health centers appreciate the opportunity to have a longer amount of time to enter data into the UDS, especially in a non-live environment that allows them to check the data regularly before submitting. This should mean fewer mistakes on the end of health centers.

International Community Health Center, Seattle, WA

This will help somewhat in familiarizing users with the form of the UDS report and with any new requirements that are evident in the form. However, since our data are not finalized until mid-January at the earliest, it will not result in us having a longer time to enter and validate data. Only a later deadline would significantly ease the time burden in UDS reporting.

Another effective strategy to reduce the burden of duplicating work (or creating re-work) would be finalizing and publishing the UDS manual prior to the reporting year so that any changes in workflow to comply with updated requirements can be made prior to the start of the reporting year.

In regards to performance measures; it would be extremely helpful to have notice of any new or changed performance measures before the beginning of the year in which they would be effective. This would allow grantees to avoid back-tracking and rethinking data collection.

Legacy Community Health, Houston, TX

Legacy supports HRSA's suggestion to open the Uniform Data System (UDS) reporting process earlier than January 1st and allow data to be entered from September 1- December 31. This change will allow health centers more time to accurately complete UDS data and ensure data is validated in a timely manner.

Mendocino Community Health Clinic (MCHC), Ukiah, CA

It would be very helpful to have more time to populate UDS. However, because some UDS elements are not quantifiable until the close of the calendar year, providing an extended time to report post-January 1, would be a more helpful change than the Bureau's proposal to allow health centers to populate early. MCHC recommends an extended UDS reporting time frame, but the extension should be an extension of the deadline, opening January 1, and closing March 15 or later.

National Association of Community Health Centers (NACHC), Washington, DC

NACHC supports opening access to the UDS reporting environment earlier than January 1.

NACHC supports providing health centers with the option of starting to submit UDS data prior to January 1. While not all health centers will be able to take advantage of this earlier window, the extended timeframe will be beneficial to those whose systems are able to use it. Health centers need to be given the option to review the data and make necessary corrections or system adjustment prior to submission to reflect accurate results. These options needs to also integrate the aspects and capabilities under section A1 – opening access to the UDS reporting environment earlier than January 1.

Neighborhood Healthcare (NHcare), Escondido, CA

It would be very helpful to have more time to populate UDS. However, because some UDS elements are not quantifiable until the close of the calendar year, providing an extended time to report post-January 1, would be a more helpful change than the Bureau’s proposal to allow health centers to populate early. NHcare recommends an extended UDS reporting time frame, but the extension should be an extension of the deadline, opening January 1, and closing March 15 or later.

Papa Ola Lokahi (POL), Honolulu, HI

In regards to RFI section A.I, we support earlier access to the UDS data-reporting environment as it will allow for the NHHCSs to ensure quality collection of data and possibly time to work with UDS data reviewers in addressing additional data categories as collected using the Native Hawaiian Health Data Card.

QueensCare Health Centers, Los Angeles, CA

Yes, HRSA should give health centers the Performance Data Collection Environment option to begin populating UDS data earlier than January 1, from September 1 to December 31. This option will give us more time to populate and validate the data to ensure accuracy, in addition to reduce staff time during the reporting process.

San Joaquin County Health Care Services Agency, Stockton, CA

While HRSA has provided earlier access to the EHB for health centers to populate data in advance of the deadline, there would be great value in pushing the deadline out further than February 15 (e.g. providing a longer period of time after December 31 to gather, analyze and populate data; March 15 or later?). Since annual UDS reports capture data from January to December, work cannot fully begin to complete the UDS report until after December 31. The current window of time only allows 45 days to complete the process; our health center could more accurately, completely and confidently submit UDS data if the deadline provided a larger window of time from December 31.

United Health Centers of the San Joaquin Valley, Parlier, CA

Yes, it would be helpful if the following conditions exist.

  • The final UDS manual is released mid-way through the reporting year to allow for early changes in reporting criteria and processes within the EHR. Currently it is an increased burden since we have to wait later in the year to assess changes and attempt to change mappings to meet the requirements.
  • If the audit alerts are currently available and functional and are able to calculate discrepancies in data entered from the same time frame last year.

Whitman-Walker Health, Washington, DC

Having the opportunity for new starts (newly-funded FQHCs) to view the UDS and understanding how it looks in the EHB could be useful. This year BPHC released the UDS guidelines earlier than in previous years, which is also useful. However, practically speaking, having the data portal open earlier — and before the reporting term ends — is not useful and could lead to double entry/incorrect data issues at submission.

 

RFI section A.2

AIDS United, Washington, DC (Legacy Community Health)

Legacy supports HRSA's suggestion for transferring UDS data directly from an entity's electronic health record (EHR) to BPHC for the purposes of annual administrative reporting. However, given the number of different EHRs that health centers use, and the complexity that interoperability creates, we recommend RFI section A.2 be an option, and not a requirement. This recommendation could have a significant, positive impact by reducing resources expended extracting data. Reporting UDS data is often done manually by hand. Having an integrated, streamlined system would save significant staff resources and allow staff to concentrate on more meaningful aspects of data collection and outcomes.

ALTURA Centers for Health, Tulare, CA

This would not be helpful from our perspective. The data we submit in the UDS has been carefully validated after extraction from our electronic health record system. If HRSA extracts the data directly from our system, we cannot assure that it is valid data.

Bi-State Primary Care Association, Montpelier, VT

While the FQHCs would generally agree that it would be a tremendous burden reduction to be able to send EHR data directly to BPHC for the purpose of UDS reporting, given the work that the PCA and the VT FQHCs have done on data feeds to our VT Health Information Exchange, we have significant concerns regarding the technical feasibility around this. Between the VT and NH FQHCs, there are seven different EHR vendors, and dozens are in use nationally. Developing EHR-specific feeds and maintaining them is a tremendous and expensive undertaking (particularly as health centers transition between EHRs approximately every 5-8 years; two VT health centers changed their EHRs just within the last six months), and it does not seem efficient to develop these feeds for a single annual report submission. HRSA funding would be better spent directed as operational funding to FQHCs and HCCNs to develop and maintain dynamic data reporting and exploration tools that could be used as part of regular daily practice for performance improvement and trending of health outcomes.

Bristol Bay Area Health Corporation, Dillingham, AK

We foresee the option of a more direct transportation of UDS data to BPHC for the purposes of annual administrative data reporting necessitating a third party vendor. As standalone EHRs don't typically have associated UDS packages which keep current with reporting methodologies/updates/data extraction capacities, a third party vendor would need to be engaged to engage the appropriate electronic data and analytic reporting platform to improve reporting efficiencies. Although this would (in theory) reduce the Community Health Center's time spent to extract and transform, integrate and submit data, the associated vendor cost may be prohibitive in light of the shrinking Community Health Center funding.

California Primary Care Association (CPCA), Sacramento, CA

CPCA member health centers are supportive of BPHC exploring technology that could streamline the UDS reporting process. However, we struggle with many concerns about patient privacy and quality of data. To alleviate these concerns, we recommend:

  • If BPHC moves in the direction of directly linking with health center EHRs, health centers must retain their ability to opt in or opt out of this electronic data feed;
  • The technology link should support the health center pushing data out of the EHR, but should not extract data. Extracting data that has not been scrubbed and vetted by the health center will lead to decreased data reliability and quality;
  • Health centers utilize a wide variety of different EHRs, and creating a technological link to each EHR would be an enormous challenge. In exploring this technology BPHC must be careful to ensure that their solution does not put small health centers with perhaps less sophisticated EHRs at a disadvantage.
  • There would be a cost associated with developing an EHR link for UDS reporting. Inasmuch as these costs will be borne by the health center, we must think of ways to ensure these costs are covered. Many CA health centers, especially smaller health centers, have thin margins and could not cover the cost.
  • Inasmuch as BPHC is planning on investing in technology, we recommend first looking at further improvements to the EHB. While the EHB has improved in the last few years, further work could be made to make it a more user-friendly product. We'd be happy to work with BPHC in providing feedback on improving the EHB.
  • It goes without saying that the data pushed to a BPHC tool by health centers must be kept extremely secure. No PHI should ever be shared over the electronic link.

Chicago Family Health Center, Chicago, IL

We welcome the option for UDS data to be directly linked through our EMR.

Community Clinic Association of Los Angeles County (CCALAC), Los Angeles, CA

CCALAC member health centers are supportive of BPHC exploring technology that could streamline the UDS reporting process. However, our health centers struggle with many concerns about patient privacy and quality of data. To alleviate these concerns, we recommend the following:

  • If BPHC moves in the direction of directly linking with health center electronic health records (EHR), health centers must retain their ability to opt in or opt out of this electronic data feed.
  • CCALAC strongly emphasizes to BPHC that the aforementioned technology link should support the health center pushing data out of the EHR, but should not extract data. Extracting data that has not been scrubbed and vetted by the health center will lead to decreased data reliability and quality.
  • Health centers utilize a wide variety of different EHRs, and creating a technological link to each EHR would be an enormous challenge. There are 13 different EHR platforms currently being used by CCALAC's member health centers. In exploring this technology, BPHC must be careful to ensure that their solution does not put health centers with less sophisticated EHRs at a disadvantage.
  • There would be a cost associated with developing an EHR link for UDS reporting. Inasmuch as these costs will be borne by the health center, we must think of ways to ensure these costs are covered. Many CA health centers, especially smaller health centers, have thin margins and could not cover the cost.
  • Inasmuch as BPHC is planning on investing in technology, we recommend first looking at further improvements to the HRSA Electronic Handbooks (EHB). While the EHB has improved in the last few years, further work should be made to make it a more user-friendly product. We would be happy to work with BPHC in providing feedback on improving the EHB.
  • It goes without saying that the data pushed to a BPHC tool by health centers must be kept extremely secure. No protected health information (PHI) should ever be shared over the electronic link.

Community Health Systems, Inc., Moreno Valley, CA

Yes, HRSA would have to explore technologies that would cater to all EH Rs for health centers. FQHCs all use different EHR software; therefore one standardized method should be considered.

Eastern Aleutian Tribes (EAT), Anchorage, AK

Since many health centers use the same E.H.R.s, it does seem like BPHC could find a way to offer an option for transporting UDS data more directly from the most common EHRs. Report standardization would save EAT time that we are currently using to extract, transform, integrate, and submit data.

Family Health Centers of San Diego, San Diego, CA

Technological innovations to streamline processes are usually a step forward, but must be taken in the context of the other priorities of the bureau. We feel that electronic transport of UDS data could prove beneficial for some, however, there are numerous barriers to success that result in us opposing this proposed solution. 1. Numerous systems – because multiple systems and multiple versions of each are used across the country, coding for all of these variables would be extremely time consuming and expensive 2. The need for multiple pathways to be developed will inevitably result in some reaping the benefits while others are left without a solution. 3. We strongly feel that any funding for technology should be focused on the EHB which, while better, is still a far cry from being a user friendly product. Lastly, and perhaps of most importance, the idea of having a governmental entity with an ongoing link to proprietary data is not something that we could support, especially given the current political climate.

Health Center Partners of Southern California, San Diego, CA

HRSA should explore technology to allow automatic extraction from individual FQ's Electronic Health Record, but please be mindful of patient privacy. There are concerns with all of the patient's medical record being accessible by the government (e.g. Mental health, HIV). There are also significant concerns, in reaction to the current political environment, that the government will have inappropriate use of other patient demographic data, such as citizenship status. Health centers provide access to all regardless of ability to pay or immigration status – per the program requirements.

Heartland Community Health Center, Lawrence, KS

In December of 2017, our center began validating UDS reports. Because there were some changes to quality measures and inclusion criteria later in the year, the EHR company does not even release updated UDS reports until after December 1 of the reporting year. Many of the approved reports have to be sent in with trouble tickets, and there were several that were not working correctly by the first due date (for eClinicalWorks v10). Some had mapping issues, others did not have all of the ICD codes listed in value sets or as specified in the HRSA approved UDS manual. In the end, there were total of 4 tables that had incorrect canned reports on the February 15 due date, and 2 of which were not solved until March 2018.

International Community Health Center, Seattle, WA

This might help somewhat in easing the administrative burden of typing all the data into the EHB form by hand. Since it is our practice to validate the data and compare data collected by our EHR vendor’s UDS tool with our own custom reports, this would be of limited usefulness in decreasing the time burden.

Legacy Community Health, Houston, TX

Legacy supports HRSA's suggestion for transferring UDS data directly from an entity's electronic health record (EHR) to BPHC for the purposes of annual administrative reporting. However, given the number of different EHRs that health centers use, and the complexity that interoperability creates, we recommend RFI section A.2 be an option, and not a requirement. This recommendation could have a significant, positive impact by reducing resources expended extracting data. Reporting UDS data is often done manually by hand. Having an integrated, streamlined system would save significant staff resources and allow staff to concentrate on more meaningful aspects of data collection and outcomes.

Mendocino Community Health Clinic (MCHC), Ukiah, CA

MCHC is supportive of BPHC exploring technology that could streamline the UDS reporting process. However, we struggle with many concerns about patient privacy and quality of data. To alleviate these concerns, we recommend:

  • If BPHC moves in the direction of directly linking with health center EH Rs, health centers must retain their ability to opt in or opt out of this electronic data feed;
  • The technology link should support the health center pushing data out of the EHR, but should not extract data. Extracting data that has not been scrubbed and vetted by the health center will lead to decreased data reliability and quality;
  • Health centers utilize a wide variety of different EHRs, and creating a technological link to each EHR would be an enormous challenge. In exploring this technology BPHC must be careful to ensure that their solution does not put small health centers with perhaps less sophisticated EHRs at a disadvantage.
  • There would be a cost associated with developing an EHR link for UDS reporting. Inasmuch as these costs will be borne by the health center, we must think of ways to ensure these costs are covered. Many CA health centers, especially smaller health centers, have thin margins and could not cover the cost.
  • Inasmuch as BPHC is planning on investing in technology, we recommend first looking at further improvements to the EHB. While the EHB has improved in the last few years, further work could be made to make it a more user-friendly product. We'd be happy to work with BPHC in providing feedback on improving the EHB.
  • It goes without saying that the data pushed to a BPHC tool by health centers must be kept extremely secure. No PHI should ever be shared over the electronic link.

National Association of Community Health Centers (NACHC), Washington, DC

NACHC supports providing health centers with the option — but not a requirement — to transfer UDS data directly from their EHRs to BPHC.

In theory, it would be a tremendous burden reduction for health centers to be able to send data directly from their EHRs to BPHC for the purpose of UDS reporting. In practice, however, a requirement to do so could be extremely costly and burdensome, for technical reasons. Health centers across the country currently use dozens of different EHR systems, and change systems on average every five to eight years. Developing and maintaining EHR-specific feeds for each of these systems would be a massive and costly undertaking, and it does not seem efficient to develop these feeds for a single annual report submission. Health centers need to be given the option to review the data and make necessary corrections or system adjustment prior to submission to reflect accurate results. These options needs to also integrate the aspects and capabilities under section A1 – opening access to the UDS reporting environment earlier than January 1.

As stated by the Vermont/ New Hampshire Primary Care Association (Bi-State PCA), a more efficient use of HRSA funding would be to provide operational funding to FQHCs and HCCNs to develop and maintain dynamic data reporting and exploration tools that could be used as part of regular daily practice for performance improvement and trending of health outcomes.

Neighborhood Healthcare (NHcare), Escondido, CA

NHcare is supportive of BPHC exploring technology that could streamline the UDS reporting process. However, we struggle with many concerns about patient privacy and quality of data. To alleviate these concerns, we recommend:

  • If BPHC moves in the direction of directly linking with health center EHRs, health centers must retain their ability to opt in or opt out of this electronic data feed;
  • The technology link should support the health center pushing data out of the EHR, but should not extract data. Extracting data that has not been scrubbed and vetted by the health center will lead to decreased data reliability and quality;
  • Health centers utilize a wide variety of different EHRs, and creating a technological link to each EHR would be an enormous challenge. In exploring this technology BPHC must be careful to ensure that their solution does not put small health centers with perhaps less sophisticated EHRs at a disadvantage.
  • There would be a cost associated with developing an EHR link for UDS reporting. Inasmuch as these costs will be borne by the health center, we must think of ways to ensure these costs are covered. Many CA health centers, especially smaller health centers, have thin margins and could not cover the cost.
  • Inasmuch as BPHC is planning on investing in technology, we recommend first looking at further improvements to the EHB. While the EHB has improved in the last few years, further work could be made to make it a more user-friendly product. We’d be happy to work with BPHC in providing feedback on improving the EHB.
  • It goes without saying that the data pushed to a BPHC tool by health centers must be kept extremely secure. No PHI should ever be shared over the electronic link.

QueensCare Health Centers, Los Angeles, CA

Yes, HRSA should consider other options for transporting UDS data directly from our EHRs to BPHC for the purposes of data reporting. Even though this might be a challenge, it could save our time and resources spent to extract the data.

United Health Centers of the San Joaquin Valley, Parlier, CA

Currently it is not a practical solution since current EMRs are not structured in a way to readily extract data from EMRs directly for clinical performance measures as of yet. Often times FQHC use a third party vendor to structure the information in an aggregated statistical fashion. This often includes weeks of validations internally before it is populated into the EHB handbook. Extracting UDS data directly without a mechanism of validation would only increase the likely hood of error.

Whitman-Walker Health (WWH), Washington, DC

For most centers, the UDS necessitates the use of multiple internal data systems. Health centers use a variety of electronic health records, electronic dental records, practice management systems, financial reporting systems, human resources information systems and platforms which extend data reporting optionality. WWH cannot ascertain the impact of directly submitting data to BPHC as compared with what is currently required of us, without knowing which data points would be targeted for direct export and the manner in which those data would be submitted. eClinicalWorks, the EHR that WWH uses, has a built-in UDS reporting function. In order to use that report, WWH would need to map all data elements to the UDS templates, which would also require major changes in workflows. WWH has not taken this step because our testing indicates that the report generated is not as accurate as the one we produce from our data warehouse. While it is possible that most of the UDS clinical and patient population data could come from an EMR-exported report, much of the required data is housed in separate financial and personnel systems. The current system of entering aggregate data into the EHB is superior given the multitude of data sources needed to complete the report. WWH recommends that the BPHC connect with the EMR vendors who serve FQHCs early in this exploratory phase in order to gain a detailed understanding of the capacity of these EMRs to produce accurate and complete dashboards and reports. Given the diversity of health center systems and the technical talent pool needed to retrieve and analyze these data sets, BPHC would likely need at least three years to implement a change and test the data validity after the change.

RFI section A.3

AIDS United, Washington, DC (Legacy Community Health)

Legacy supports HRSA's suggestion to streamline and avoid duplication among UDS Tables, such as the suggested consolidation among UDS Table 6A elements and content in Table 6B. This is an important change because the duplicate information in two separate tables causes inconsistencies in data reporting and can be time-consuming to correct. The consolidation of tables will help streamline reporting without compromising the degree of data collected.

ALTURA Centers for Health, Tulare, CA

Having entered UDS data through the EHB over many years, I do not feel there is much duplication in data entry from one table to another. Each table requires specific data to be entered.

Bi-State Primary Care Association, Montpelier, VT

If HRSA pursues the idea of an anonymous database, with funding, HCCNs may have a role in exporting health center data into this new repository. With the integration of SUD/MAT services, there may be further considerations re: 42 CFR Part 2, as health centers often do not differentiate between the treatment of their SUD patients and the treatment of their other patients. Consequently, data is comingled, and 42 CFR Part 2 could be a factor for all data in the EHR and, potentially, HRSA’s database.

Finally, the health centers noted that it would be helpful if more logic was built into the UDS report, so that the system recognizes patterns from year to year. There are some trends that it recognizes, but this could be expanded. One health center executive noted that she submits over three pages of data audit notes each year, and that these notes explaining the data are very often repetitions from previous years.

Bristol Bay Area Health Corporation, Dillingham, AK

Support all efforts to reduce duplication of reporting single data elements on multiple different UDS Tables. It appears that improved data algorithms within the current reporting platform could improve things in this regard (get the Tables to "talk" and/or cross-populate automatically).

California Primary Care Association (CPCA), Sacramento, CA

CPCA supports allowing the UDS tables to auto-populate other tables, which could avoid duplicity and errors when validating data. We note that it’s absolutely critical to ensure that the auto-populated data remains modifiable by health centers.

We also support HRSA re-aligning tables 6A and 6B with the clinical performance measures as worded by the recently updated site visit protocol and health center program compliance manual, and recommend deleting table 5A as having no value for health centers.

Finally, we would like to better understand if and how this would impact UDS QI Awards, which are based on results found in table 6B and 7.

Chicago Family Health Center, Chicago, IL

Agree that there is duplication between Table 6A and 6B, and that the data in Table 6A is of lesser value to FQHCs.

Community Clinic Association of Los Angeles County (CCALAC), Los Angeles, CA

CCALAC supports allowing the UDS tables to auto-populate other tables, which could avoid duplicity and errors when validating data; however, it is absolutely critical that the auto-populated data remains modifiable by health centers.

We also support HRSA re-aligning tables 6A and 6B with the clinical performance measures as worded by the recently updated site visit protocol and health center program compliance manual.

Finally, CCALAC requests clarification from BPHC whether the above proposed changes would impact future UDS QI Awards, which are based on results found in table 6B and 7.

Community Health Systems, Inc., Moreno Valley, CA

Yes, HRSA should allow information from one table to auto-populate to other relevant tables to avoid duplicity and multiple errors when validating. Yes, HRSA should re-align tables GA and 6B with the clinical performance measures as worded by the recently updated site visit protocol and health center program compliance manual.

Eastern Aleutian Tribes (EAT), Anchorage, AK

EAT supports the idea of being able to more efficiently extract patient data to populate multiple tables in the UDS. Duplicate content should be reduced, so it only shows up in one Table to help reduce the length of the report and the time it takes to complete the report.

Family Health Centers of San Diego, San Diego, CA

Reducing reporting burden is normally always welcome. If the bureau is proposing eliminating certain data points that it feels are duplicative, we would agree with that approach, however the proposed changes, unless not fully explained in the RFI, make no sense. Even the example given in the RFI – Table 6A, pap tests administered and Table 6B, the cervical cancer clinical quality metric are not equivalent. There are numerous women for which we meet the metric but which we haven't administered the pap test (test administered elsewhere with verifiable evidence of such). With regard to decreasing the reporting burden required by the bureau we feel the biggest area of opportunity for reduction would be the unnecessary carryover requests required by 330 supplemental awards that are awarded across two budget periods. A supplemental award is issued, usually with a specific one year period that almost inevitably crosses over two 330 budget years. Work on the supplemental award is supposed to occur over the one year award period, however we are required to submit a carryover budget and then justify why we didn't spend the money in the current 330 budget year, and identify how we are going to spend the money in the coming 330 budget year. The response should simply be that the grant was expressly awarded for that period and funds are being expended in accordance with the project time line, yet HRSA requires a more in-depth analysis as outlined above. This process unnecessarily creates additional work for grantees, Project Officers and Grants Management Specialists alike. We would highly recommend that HRSA adopt the approach of SAMHSA, which is to allow automatic carryover of amounts less than 10% of that year's award, without prior approval.

Health Center Partners of Southern California, San Diego, CA

It would be immensely helpful if HRSA would auto-populate tables to reduce the burden of entering duplicate information. It could also cut down on errors.

Health centers believe that the diagnoses and services rendered table 6A does a good job of illustrating the variety and complexity of services provided for the health center population and should remain.

Heartland Community Health Center, Lawrence, KS

In reference to Table 6A, there are some measures that do overlap, but the values in 6A vs 6B are very different (especially for clinics that have to refer for services). Additionally, the restrictive codes for 6A do not necessarily include all codes encompassed by the issues (for example, SBIRT codes are difficult to use because many payors will not pay out so the reported # is 0, but we adopted templates to include SBIRT workflows resulting in 204 SBIRT visits and 184 SBIRT patients; also the Z72.0 tobacco use code does not count for tobacco use disorder, skewing our numbers by 600 fewer patients being reflected in this table – a 207% difference in reported vs. actual )

International Community Health Center, Seattle, WA

Using data entered into one table to populate other sections of the report would be a significant reduction of time spent entering and re-checking data for consistency between tables. The proposed elimination of some elements of Table 6A would also help in this regard.

Legacy Community Health, Houston, TX

Legacy supports HRSA's suggestion to streamline and avoid duplication among UDS Tables, such as the suggested consolidation among UDS Table 6A elements and content in Table 6B. This is an important change because the duplicate information in two separate tables causes inconsistencies in data reporting and can be time-consuming to correct. The consolidation of tables will help streamline reporting without compromising the degree of data collected.

Mendocino Community Health Clinic (MCHC), Ukiah, CA

MCHC supports allowing the UDS tables to auto-populate other tables, which could avoid duplicity and errors when validating data. We note that it's absolutely critical to ensure that the auto-populated data remains modifiable by health centers.

We also support HRSA re-aligning tables GA and 6B with the clinical performance measures as worded by the recently updated site visit protocol and health center program compliance manual, and recommend deleting table SA as having no value for health centers.

Finally, we would like to better understand if and how this would impact UDS QI Awards, which are based on results found in table 6B and 7.

National Association of Community Health Centers (NACHC), Washington, DC

NACHC supports creating more efficient algorithms to extract health center primary data to populate multiple UDS tables, but requests that traditional UDS reporting mechanisms be retained until the data produced by the algorithms is representative of important subpopulations.

NACHC supports the idea of creating more efficient algorithms to extract health center primary data (clinical visits and socio-demographic data) to populate multiple UDS tables. These algorithms need to be centralized and validated to ensure they reflect actual efforts. At the same time, we urge HRSA not to abandon traditional methods for UDS reporting until there is confidence that the results produced by the algorithms are representative not only of the full universe of health center patients, but also of important subpopulations (e.g., states, localities, urban areas, rural areas, special populations.)

NACHC does not support BPHC's proposal to eliminate some or all of the measures on Table 6A.

While we appreciate BPHC's goal of reducing reporting burden on health centers, NACHC does not support BPHC’s proposal to eliminate some or all of the measures on Table 6A. Tables 6A and 6B serve distinct purposes, with the former documenting the extent to which health centers provide key services, and the latter aligning with national quality metrics. We are concerned that valuable data would be lost if some or all of the measures in Table 6A were eliminated.

Neighborhood Healthcare (NHcare), Escondido, CA

NHcare supports allowing the UDS tables to auto-populate other tables, which could avoid duplicity and errors when validating data. We note that it's absolutely critical to ensure that the auto-populated data remains modifiable by health centers.

We also support HRSA re-aligning tables 6A and 6B with the clinical performance measures as worded by the recently updated site visit protocol and health center program compliance manual, and recommend deleting table 5A as having no value for health centers.

Finally, we would like to better understand if and how this would impact UDS QI Awards, which are based on results found in table 6B and 7.

Papa Ola Lokahi (POL), Honolulu, HI

While the suggestion is being made in RFI section A.3 to retire some of the clinical information, we would like to propose creating a space for additional and ultimately unique data sets that may not necessarily reflect the work being clone by a service organization in the overall UDS collection method. With a better collection and dissemination of data, policymakers and community organizations will be able to initiate targeted support to those within medically underserved areas and populations who need it most.

QueensCare Health Centers, Los Angeles, CA

Yes, HRSA should reduce reporting burden by extracting patient data from a database to populate multiple tables in the UDS. It will save time and resources. Also, HRSA should eliminate duplicated contents in tables 6A and 6B.

United Health Centers of the San Joaquin Valley, Parlier, CA

Yes, allowing information in one table to automatically populate others would reduce the reporting burden by eliminating duplication and rework. It would also reduce the likelihood of errors due to manual entry in many of the corresponding tables.

Removing 6A tables would reduce the burden on our health center since this table is not reflective of total services rendered. The requirement of selected codes does not give a complete picture of care that is provided. Table 6B is a more reliable way of understanding the care we provide to our patient population for clinical performance measurement. 6 B currently allows the practice to count if applicable outside services completed toward our numerators; example colonoscopies and cervical cancer screenings.

Whitman-Walker Health (WWH), Washington, DC

WWH welcomes the automation of data tasks as long as the algorithms can be shown to statistically comparable to our current measurements and centers are able to participate in the design and testing phase. Whether changes would be beneficial will depend on what data algorithms are used, what kinds of human resources would need to be in place in order to validate and monitor the extraction on the health center side, and the extent to which these algorithms would necessitate a change to current clinical documentation practices.

WWH does not find the production to Table 6A to be particularly burdensome, from a technical point of view. Many of the variables in Table 6A measure quantities – for example, numbers of people who have HIV. They do not, however, measure quality – for instance, how many people with HIV have achieved viral suppression. Quantities are of some interest to us on the health center side but are not as actionable or impactful as the quality outcome information tabulated in Table 6B. Although there is some overlap between the two Tables, any efforts to streamline what is reported in Table 6A and Table 6B should focus on the quality of the care delivered, and should be guided by a team of medical, behavioral, and dental health care clinicians.

Date Last Reviewed:  October 2018