Hattis criticism of DPH off the mark
Agency focused on cost-benefit, not just costs
THE CRITICISM of the Department of Public Health that was recently published in Commonwealth may have struck a nerve, but it fell far wide of the mark.
The article, “DPH needs to stop being a paper tiger,” was written by Paul Hattis, a former commissioner of the Health Policy Commission. He recommends that the Legislature transfer the responsibility of approving or denying certain health care provider capital, bed, and service expansion projects from DPH to the Health Policy Commission. I disagree with his recommendation. He fails to explain the differences in the roles of the two agencies and believe that the DPH, through its commissioner, senior staff, and the Public Health Council, does indeed have the skills, expertise, and commitment to take on tough health care issues.
My understanding of the differences in the roles of the two agencies stems from my 12 years of experience as a member of the Public Health Council as well as years spent as an emergency physician and health care leader and administrator. The regulatory process has been developed so that, for the type of projects identified in the Hattis article, the Health Policy Commission has an important role to provide DPH and the Public Health Council with substantive comments that are to be considered in the DPH review and decision-making process.
The Health Policy Commission was created by the Legislature in 2012 with a mission to control health care cost growth. The commission produces an annual cost trends report and sets an annual target for cost growth that providers must abide by or face sanctions. The commission has the primary responsibility to review many transactions between health care providers for cost and market impact, and it issues periodic reports on various subjects chosen by their staff, described in their website “as part of our cost-control efforts.”
Costs are relatively easy to count. Costs are a linear and cumulative compilation of money spent.
Benefits, on the other hand, are often more difficult to quantify: it’s far more complicated to put a monetary number on a longer life, a life improved by access to appropriate care, a life with less pain, or a renewed ability to engage in physical activity after a joint replacement. It is far more complicated to measure in monetary terms the value of simply being alive compared to the alternative.
In contrast to the Health Policy Commission, DPH’s fundamental mission is to promote the health of Massachusetts residents. DPH pursues its missions in multiple ways: promoting vaccines, anti-smoking eﬀorts, coordinating responses to specific health threats, and regulating hospitals, nursing homes, clinics, labs, etc. to ensure quality and access to care and much more.
In 2020, DPH and the Public Health Council led the way in helping the Commonwealth meet the COVID-19 pandemic head-on and DPH worked tirelessly to assist health care providers in their eﬀorts to combat the pandemic. DPH continues to play this role and we are all better because of it.
DPH also rules on significant health care provider construction, bed, and service expansion projects through a process known as determination of need. Determination of need is a balanced analysis of both costs and benefits, evaluating projects based on the health care and public health needs of patients. As indicated above, cost analyses are part of the process with substantive input from the Health Policy Commission and, when needed, DPH chooses an outside economist to perform an independent cost analysis, the expense of which is borne by the provider.
In 2017, the DPH determination of review process was significantly strengthened to provide improved tools to review significant health care provider projects. The Public Health Council, which has final decision-making authority with respect to determination of need projects, will review the staff recommendations and, if voting to approve a project, can decide to impose additional requirements or oversight to ensure that the DPH goals of improving access to care and public health value are addressed.
The 2021 version of the determination of need process is designed to help ensure that heath care providers undertake projects that address pressing public health needs, are quality driven, and as cost effective as possible
As part of DPH’s aggressive efforts to improve access to care and improve public health, the determination of need program requires a set-aside of 5 percent of total project costs for community health initiatives which are likely to focus on behavioral health needs, access to care, the opioid crisis, nutrition programs, and other social determinants of health.DPH and the Public Health Council have the requisite expertise and resources to determine if the projects are needed or not. As previously stated, DPH’s overall mission is to improve public health. This is what the DPH determination of Nned program is all about, increasing access to needed services in a cost-effective manner. DPH and the Public Health Council perform important roles in the health care system and its future. These roles should be preserved and, if necessary, improved, not dismantled.
Dr. Alan Woodward was a member of the Public Health Council from 2007 to 2019 and was chief of emergency services at Emerson Hospital for 18 years, from 1989 to 2007. He was also president of the Massachusetts Medical Society from 2004 to 2005.