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PA Bulletin, Doc. No. 99-564



Notice of Comments Issued

[29 Pa.B. 1800]

   Section 5(g) of the Regulatory Review Act (71 P. S. § 745.5(g)) provides that the designated standing committees may issue comments within 20 days of the close of the public comment period, and the Independent Regulatory Review Commission (Commission) may issue comments within 10 days of the close of the committee comment period. The Commission comments are based upon the criteria contained in section 5a(h) and (I) of the Regulatory Review Act (75 P. S. § 745.5a(h)(I)).

   The Commission has issued comments on the following proposed regulations. The agency must consider these comments in preparing the final-form regulation. The final-form regulations must be submitted by the dates indicated.

Reg. No. Agency/Title
Issued Deadline
100-14 Pennsylvania Health Care
   Cost Containment Council
      Severity Methodology
3/18/99 2/16/01
(Notice of proposed rulemaking published at 29 Pa.B. 332 (January 16, 1999))

Pennsylvania Health Care Cost Containment Council Regulation No. 100-14

Severity Methodology

March 18, 1999

   We have reviewed this proposed regulation from the Pennsylvania Health Care Cost Containment Council (Council) and submit for your consideration the following objections and recommendations. Subsections 5.1(h) and 5.1(i) of the Regulatory Review Act (71 P. S. § 745.5a(h) and (i)) specify the criteria the Commission must employ to determine whether a regulation is in the public interest. In applying these criteria, our Comments address issues that relate to clarity and economic impact. We recommend that these Comments be carefully considered as you prepare the final-form regulation.

§ 911.1.  Definitions.--Clarity and Economic Impact

''Patient severity''

   The proposed amendment to the existing definition of ''patient severity'' contains phrases such as ''appropriate clinical findings'' and ''any other relevant clinical factors.'' These phrases are vague. What are the parameters of an ''appropriate'' clinical finding or a ''relevant'' clinical factor?

   Further, it is not clear from these phrases if the Council intends to consider other severity measurement methodologies, such as administratively based systems, when the definition of ''patient severity'' emphasizes ''clinical'' findings and factors.

   The Hospital and Healthsystem Association of Pennsylvania and the Hospital Council of Western Pennsylvania have both suggested revisions to this definition that would allow the Council to review and select alternative methodologies to determine patient severity. The use of an alternative methodology could reduce duplicative record reviews, saving hospitals as much as $40--50 million annually.

   We question how the Council will achieve its stated purpose if the definition is so narrow that it does not allow the Council flexibility in the selection of patient severity adjustment methodology. For these reasons, the Council should amend the definition of ''patient severity'' to more clearly allow the Council the latitude to choose the most cost effective patient severity methodology.


[Pa.B. Doc. No. 99-564. Filed for public inspection April 2, 1999, 9:00 a.m.]

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