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Comparative Health System Performance in Accelerating PCOR Dissemination (U19)

Frequently Asked Questions


The following FAQ is derived from individual questions submitted to AHRQ about the Comparative Health System Performance in Accelerating PCOR Dissemination (U19) during the August 22, 2014, technical assistance conference call.

 


 

Contents 

Questions on TIN and Other Identification Numbers
     General Answer
Other Questions
Question Regarding Flexibility in the Investigator Support
Administrative Cost Question

 

Questions on TIN and Other Identification Numbers

Q: One of the review criteria is does the application include a plan to share Tax Identification Numbers and physician NPIs. There are nice data sets that are probably possible to acquire to get a DUA under certain restrictions where the analyses would not identify hospital or physician groups per se. I can imagine getting those in the timeline to submit an application. Getting something where those data and Tax Identification Numbers and NPIs would be passed onto AHRQ is another level of data sharing that is probably a larger conversation. So, I guess if you have data that you can obtain where it’s not entirely clear that the Data Use Agreement allows for passing on Tax Identification Numbers and NPIs to AHRQ, does that mean that that’s not responsive?

A: That would be considered responsive.  We will evaluate applications that are unable to provide identifiers. We recognize that there are many unknowns and applicants may not be able to complete a DUA before submitting the application.  The applicant should lay out their plans for providing TINs and physician NPIs to the Coordinating Center, and applicants may include letters of support from systems indicating discussions are underway to develop DUAs.  If applicants cannot supply identifiers, they must justify why they are unable to do so  due to DUA restrictions.  The burden of proof will be on the applicant to justify how their proposed approach is responsive to the FOA.

Q:  So let’s say any of us had a set of participating organizations that they’ll provide data and we can identify who they are but they are uncomfortable with us identifying - attaching a name to a set of characteristics about that organization. So we would characterize the sample but we would not be able to tell AHRQ that Plan Number 4 looks like X.  Is that non-responsive?

A: That would be considered responsive.  However, in their analytic plan, applicants must justify why they are unable to supply organization names.   If an applicant’s data use agreements do not permit sharing of system names with the Coordinating Center, the burden of proof will be on the applicant to justify how their proposed approach is responsive to the FOA.

Q: Are analytical results required to be tied to NPIs?

A:  No.

Q: I was wondering if you could say a bit more about the compendium of health systems across the country. You indicated that the projects would be compiling data including identifiers for the providers in these health systems.

One of the concerns that I know I’ve encountered in the past in dealing with health systems and trying to elicit the type of information is much of this information will be considered sensitive. I was wondering if AHRQ had thought about data sensitivity issues.

And

Q: Does AHRQ wish to go beyond the identification of respondents to collecting data that links specific outcome measures to each identified respondent?  In many instances the U19 will be eliciting information from organizations that expect such measures to only be used for statistical analyses, i.e., without outsiders being able to link specific results to a specific organization.  Please clarify this Data Core requirement in the context of the AHRQ confidentiality statute, 42 USC 299c-3(c).

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General Answer:

A: Under the cooperative agreement, grantees will be expected to share analytic results with a Coordinating Center contractor for purposes of creating a compendium of information that can be used to inform PCOR dissemination strategies, so that systems can more quickly adopt high-performance practices and improve patient outcomes. This “systems compendium” will be put together by the Coordinating Center.  The goal is for the compendium to be able to link and/or combine data to make it possible to create a cross-project aggregate picture of system characteristics and outcomes.  Where possible and permissible under their data use agreements, we expect applicants to provide the Coordinating Center with the names of the health systems they studied as well as relevant identifiers (e.g., Medicare hospital identifiers and physician NPIs), along with outcome measures and systems’ performance on these measures.  The main purpose of requesting system names is to be able to link information gathered by one grantee about a particular system with information potentially gathered by other grantees or by the coordinating center about the same system.  The main purpose of requesting information that identifies the hospitals and physicians that comprise the system is to be able to assess, if two grantees report results for a system with the same name, whether they are reporting on the same (or at least a similar) set of providers. 

The FOA requests the applicant to “include a plan to share analytic results, tax identification numbers (TINs), and physicians’ national provider identifiers (NPIs) with the Coordinating Center for the systems compendium.” As stated above, if the terms of the DUAs prevent applicants from sharing some or all of this information, applicants shall acknowledge that.   If an applicant’s data use agreements do not permit sharing some or all of this information, the burden of proof will be on the applicant to justify how their proposed approach is responsive to the FOA.

Analytic results should be tied to the appropriate identifiers when shared with the Coordinating Center.  The AHRQ confidentiality statute, 42 USC 299c—3(c), requires that information that is obtained in the course of AHRQ-supported activities and that identifies individuals and establishments be used only for the purpose for which it was supplied.  Thus, the plan should outline any DUA and IRB requirements for involving the (as of now, unnamed) researcher(s) of the Coordinating Center in the data collaboration. Applicants are responsible to ensure that the terms of the DUA governing consent to engage in data analysis and permissive disclosure support the collaborative research requirements stated in the FOA, including the involvement of AHRQ program personnel.  This collaboration may involve the Coordinating Center linking/appending the U19’s contributed data results and identifiers with data from other U19’s and data from AHRQ or from analysis conducted by the Coordinating Center to form a compendium, for the purposes of the Coordinating Center doing wider statistical analyses across many more systems, and then reporting results in collaboration with the U19 researchers.   Information supplied by a U19 grantee to the Coordinating Center that identifies health systems or hospitals by name will not be made public  without the express consent of the grantee and the health system or hospital involved.  Information on individual physicians will not be made public under any circumstances. 

As discussed above, if DUAs do not allow grantees to share identifying information on health systems, the applicants should acknowledge this.  The burden of proof will be on the applicant to justify how their proposed approach is responsive to the FOA.

If the grantee does not have, or cannot share, identifying information on the providers included in the systems studied, the grantee should present a plan to allow the Coordinating Center to determine whether the system studied by one grantee includes a similar set of providers to a system with the same name studied by another grantee. 

 

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Other questions:

Q: We assume AHRQ wishes to know more than just the “class” of organizations in the sampling frame, e.g., large medical groups.  Will this requirement be met by providing the name and other identifying information for each organization in the sampling frame, or must this list be limited to those providing at least some data, i.e., responding to the survey? 

A: As discussed above, the goal is to be able to link and/or combine data to make it possible to create a cross-project aggregate picture of system characteristics and outcomes.  Where possible and permissible under their data use agreements, we expect applicants to provide the Coordinating Center with the names of the health systems they studied as well as relevant identifiers (e.g., Medicare hospital identifiers and physician NPIs), along with outcome measures and systems’ performance on these measures.  The main purpose of requesting system names is to be able to link information gathered by one grantee about a particular system with information potentially gathered by other grantees or by the coordinating center about the same system.  The main purpose of requesting information that identifies the hospitals and physicians that comprise the system is to be able to assess, if two grantees report results for a system with the same name, whether they are reporting on the same (or at least a similar) set of providers.  In the case of survey data, we would like applicants to identify the non-respondent systems as well as the respondents, and to convey that to the Coordinating Center.  The main purpose of this request is to provide an opportunity for the Coordinating Center to be able to compare characteristics of the respondent vs non-respondent systems using other data that may be available, as well as to fill in any gaps through other data sources.  We do not request that names of the individuals completing the survey be provided.

 

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Question Regarding Flexibility in the Investigator Support

Q: Our five-year budget will have clearly identified investigators for the PI, Data Core and Project Leads with committed percentage efforts.  There will be additional named investigators working on specific aspects of the projects.  This should allow the proposal reviewers to assess our overall approach.

Would it be acceptable for us to set aside some funding in years 4 and 5 for TBN investigators with specific expertise to undertake certain work in response to opportunities arising between now and then, but that are impossible to identify at the current time?  Some of these “TBN investigator” funds may be allocated to existing personnel, but this will depend on the nature of the research opportunities.  The “TBN investigator” funds would be less than 25% of the total and would not negatively impact the support committed for the PI, Data Core, and Project Leads.

 

A: It is unallowable to have “set-aside” (i.e., contingency) funds under a grant.  AHRQ will not obligate funds for a grant (or cooperative agreement) in a current or a future period budget period for unknown or contingent activities of the recipient.  If contingency funds are budgeted, they will be deemed “unallowable costs” and removed from the award; unallowable costs are not allowed to be rebudgeted. However, it is permissible to budget for unnamed investigators or researchers.  That is, the budget could list a line item for a ‘social science analyst’, or a ‘statistician’, or a ‘survey methodologist’ without having a specific name attached to the position.  In the budget justification, the responsibilities of the proposed personnel would need to be described, just as they would be for named investigators. 

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Administrative Cost Question

Q. Should all administrative costs related to the grants management/coordination across the individual projects be included in the Data Core budget?

A. Yes.

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Page last reviewed September 2014
Internet Citation: Comparative Health System Performance in Accelerating PCOR Dissemination (U19): Frequently Asked Questions. September 2014. Agency for Healthcare Research and Quality, Rockville, MD. https://archive.ahrq.gov/funding/fund-opps/rfahs14011faq.html

 

The information on this page is archived and provided for reference purposes only.

 

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