BILL ANALYSIS Ó AB 2670 Page 1 Date of Hearing: April 27, 2016 ASSEMBLY COMMITTEE ON APPROPRIATIONS Lorena Gonzalez, Chair AB 2670 (Roger Hernández) - As Introduced February 19, 2016 ----------------------------------------------------------------- |Policy |Health |Vote:|16 - 0 | |Committee: | | | | | | | | | | | | | | |-------------+-------------------------------+-----+-------------| | | | | | | | | | | | | | | | ----------------------------------------------------------------- Urgency: No State Mandated Local Program: NoReimbursable: No SUMMARY: This bill requires the Department of Health Care Services (DHCS) to administer, on an annual basis, the Consumer Assessment of Health Care Providers and Systems (CAHPS) Health Plan surveys, as developed by the federal Agency for Healthcare Research and Quality for all Medi-Cal managed care plan (MCP) populations. Specifically, this bill: AB 2670 Page 2 1)Requires DHCS to annually administer the CAHPS survey to all MCP models, including county organized health systems (COHS), two-plan models, and geographic managed care plans. 2)Requires DHCS to translate the CAHPS survey in all Medi-Cal threshold languages and requires DHCS to administer the CAHPS survey in all Medi-Cal threshold languages in each county. 3)Requires DHCS to stratify the results in order to identify disparities in the quality of care provided to Medi-Cal managed care enrollees based on all of the following factors: a) Geographic region; b) Primary language; c) Race; d) Ethnicity; e) Gender; and, f) To the extent data is available, sexual orientation and gender identity. 4)Requires DHCS to annually prepare and make publicly available a report on the results of the surveys on the DHCS Website. Provides that the report will include all of the following: a) Aggregated data on MCP results compared to national Medicaid data; b) Aggregated MCP results stratified by the factors set forth as specified; and, c) Plan results at the county level, including results for all MCP models, as specified. FISCAL EFFECT: 1)Costs, likely in the range of $500,000- $1 million annually to conduct the survey every year in multiple languages. The AB 2670 Page 3 survey is currently conducted every three years and costs $500,000 to administer in English and Spanish. 2)Unknown, significant one-time costs to translate surveys into thirteen threshold languages. As discussed further below, costs would depend on whether validated translations exist or would have to be developed, and the extent of field testing prior to implementation. 3)Unknown, significant ongoing costs associated with the requirement to stratify by a number of variables. Performing an estimate of the increased sample size needed to ensure the ability to stratify results to identify disparities in care is beyond the scope of this analysis, but costs could be very high if a high level of oversampling is required in order to ensure results can be meaningfully stratified. COMMENTS: 1)Purpose. The author states that this bill gives us the opportunity to assess California's most diverse populations and different health care needs. Furthermore, the author states that Medi-Cal's quality measures must be consistent and reflect everyone's health care experience, as one in three Californians is now enrolled in Medi-Cal. 2)Background. The CAHPS survey assesses both patient satisfaction and perceptions of access to care, and the survey exists for hospitals, managed care plans, and other providers. In Medi-Cal managed care, CAHPS measures assess the experiences of surveyed managed care plan members in the prior six months. Members are asked questions like, "How often was it easy to get necessary care, tests, or treatment?" or "How would you rate your health plan?" Currently, DHCS conducts AB 2670 Page 4 the CAHPS survey once every three years in two languages, English and Spanish. DHCS publishes the results on its website and uses results as part of its Medi-Cal Managed Care Program Quality Strategy and to recognize plan quality improvement. 3)Staff Comments. Data collection can provide valuable insight into program operation, but does come with a cost. The requirements of this bill address several items: a) This bill increases the frequency of the CAHPS survey. This is consistent with LAO recommendations and appears warranted given significant changes in enrollment, networks, and overall impacts on Medi-Cal managed care plan operations. b) This bill also requires the survey to be translated into all Medi-Cal threshold languages, and administered in each county in all Medi-Cal threshold languages in that county. This is beneficial because it allows the opinion of Medi-Cal enrollees who do not speak English or Spanish to be counted in the poll. However, it is unclear whether validated translations exist in languages other than in Spanish. Survey instruments must be validated through psychometric testing, and surveys such as CAHPS have been very well-tested. The agency for Healthcare Research and Quality, which houses CAHPS, offers guidelines for translating CAHPS surveys into other languages. These include the use of two simultaneous translators and a translation review to ensure the quality and cultural appropriateness of the translated instrument, as well as subject the translated instrument to qualitative analysis and psychometric testing to gauge the reliability, validity, and equivalence of the instrument in measuring the health needs of various subgroups. Thus, while translation is certainly possible, translating a survey is AB 2670 Page 5 quite involved. Questions and responses translated into each threshold languages are not guaranteed to directly map to the English version without significant effort to carefully translate and test the surveys. It should be noted a small number of Medi-Cal enrollees would be sampled for any CAHPS survey, making the chances small that some languages would be represented. c) Finally, this bill requires stratification of results in order to identify disparities in the quality of care provided to Medi-Cal managed care enrollees based on the factors: geographic region, primary language, race, ethnicity, and gender, as well as sexual orientation and gender identity to the extent data is available. Stratification is different than simply including a diverse population in the sample, as addressed in (b) above. Stratification would theoretically allow one to measure, for example, how persons of a particular ethnic group perceive care in a particular plan. CAHPS is designed to measure enrollees' recent experiences with health plans and their service, to support consumers in choosing a plan, and identify areas of quality improvement for plans. However, the LAO report notes that DHCS has not even been able to stratify by health plan given the sample size they've used, let alone by subpopulations within a plan. Depending on the goals, stratification by these sub-categories may likewise either be impossible due to limited sample size or, if sample size was increased in order to collect enough data to allow stratification for the many variables of interest, data collection could become prohibitively expensive. For example, to compare perceptions about the timeliness of care between Fresno County Hmong-speaking individuals and persons speaking other languages, the survey would need to include a sufficient number of Hmong speakers from Fresno County. Without oversampling small populations of AB 2670 Page 6 interest, it is difficult to collect enough data to report anything meaningful about members of these small populations. For comparison's sake, the California Health Interview Survey is conducted in English, Spanish, two Chinese dialects, Korean, and Vietnamese. Other languages can be added on a pilot basis, and Korean and Vietnamese, as smaller language groups, are oversampled. Given the potentially high cost of requiring sufficient sample sizes to be able to stratify by the listed variables, staff recommends the author consider clarifying that stratification is only required if the sample size is large enough to report meaningful results. Special one-time surveys could be conducted whereby certain populations of interest are oversampled, allowing for stratification if there are particular areas of concern, instead of requiring a costly level of data collection on an ongoing basis. Analysis Prepared by:Lisa Murawski / APPR. / (916) 319-2081