The influence of records on medical charts as a factor associated with technical disallowances / La influencia de los registros en la historia clínica como uno de los factores que se asocia al fallo técnico hospitalario / A influência dos registros do prontuário como um dos fatores associados à glosa técnica hospitalar

ABSTRACT Objective: identify the influence of records in medical charts as one of the factors associated with technical disallowances. Method: quantitative, analytical, cross-sectional field study conducted in 2018 in two hospitals. A total of 324 payment statements were analyzed, considering five health plan operators in each hospital. These statements contain the codes of disallowances provided in the TISS [Exchange of Information on Supplementary Health] Table. Results: technical disallowances concerning materials were higher than those concerning medications in hospitals 1 and 2, 90.99% and 84.79%, respectively. The factors associated with technical disallowances were hospital stay — p=0.001 in hospital 1 and p=0.01 in hospital 2 — and type of hospitalization in hospital 2, p=0.000. Hospital 1 amounted to R$2,305.61 (2.28%) of disallowances in nine medical charts. However, all the medical charts contained the records of technical reports, which can be appealed. A different result was found for hospital 2, where 43 medical charts totaled R$31,181.14 (17.82%) of disallowances, R$3,096.13 of which concern missing codes (material and medication); hence, no appeal is possible, resulting in financial loss. Conclusion: the monetary amounts of technical disallowances were higher in both hospitals. There is evidence that the length of hospital stay generates disallowances. Therefore, the records in medical charts influence disallowances, and missing records lead to financial loss. TISS standardizes the reasons for disallowances, favoring justifications to appeal, and facilitates the analysis of records and controls of payments to the services provided.

RESUMEN Objetivo: identificar la influencia de los registros en las historias clínicas como uno de los factores asociados al fallo técnico. Método: estudio cuantitativo analítico, de campo, transversal, en el año 2018, en dos hospitales. Se analizaron 324 extractos de pago, con cinco operadores de cada hospital. En estas declaraciones se describen los códigos del fallo que hacen referencia a la Tabla de Dominio de Intercambio de Información Sanitaria Suplementaria (TISS). Resultados: en los hospitales 1 y 2, el fallo técnico del material fue superior a la de la medicación, siendo del 90,99% y del 84,79%, respectivamente. Los factores asociados al fallo técnico fueron la duración de la estancia; p = 0,001 en el hospital 1 y p = 0,01 en el hospital 2, y el tipo de ingreso en el hospital 2 con p = 0,000. El Hospital 1 presentó R$ 2.305,61 (2,28%) de fallos en nueve historias clínicas. Sin embargo, todos presentaron registros de informe técnico, las cuales pueden ser apeladas. Resultados diferentes en el hospital 2, donde se han encontrado 43 historias clínicas, por un valor de R$ 31.181,14 (17,82%) y, de este valor, R$ 3.096,13 se refieren a los códigos de material y de medicamentos, no teniendo registros en las historias clínicas y no siendo posible apelar, acarreando pérdidas. Conclusión: en los dos hospitales, el valor del fallo técnico del material fue mayor. Hay pruebas de que el tiempo de permanencia puede generar fallos, y en cuanto al registro en la historia clínica, este influye en el fallo y, cuando falta, genera una pérdida financiera. El uso del TISS normaliza los motivos de los fallos, favorece la realización de la justificación del recurso, facilita el análisis de los expedientes y ayuda a controlar el pago del servicio prestado.

RESUMO Objetivo: identificar a influência dos registros no prontuário como um dos fatores associados à glosa técnica. Método: estudo quantitativo analítico, de campo, transversal, realizado no ano de 2018 em dois hospitais. Foram analisados 324 demonstrativos de pagamento, sendo cinco operadoras de cada hospital. Nesses demonstrativos, estão descritos códigos de glosa referentes à Tabela de Domínio de Troca de Informações de Saúde Suplementar (TISS). Resultados: nos hospitais 1 e 2, a glosa técnica de material foi maior que a de medicamento, sendo 90,99% e 84,79%, respectivamente. Os fatores associados à glosa técnica foram o tempo de permanência — p = 0,001 no hospital 1 e p = 0,01 no hospital 2 — e o tipo de internação no hospital 2, com p = 0,000. O hospital 1 apresentou R$ 2.305,61 (2,28%) de glosa em nove prontuários. Contudo, todos apresentaram registros de relatório técnico, que pode ser recursado. O resultado foi diferente do hospital 2, onde foram glosados 43 prontuários, no valor de R$ 31.181,14 (17,82%); desse valor, R$ 3.096,13 são referentes aos códigos de material e de medicamentos, não havendo registros em prontuários e não sendo possível fazer recurso, acarretando perda. Conclusão: nos dois hospitais, o valor da glosa técnica de material foi maior. Há evidência de que o tempo de permanência pode gerar glosa. Quanto ao registro no prontuário, este influencia na glosa e, quando ausente, gera perda financeira. A utilização do TISS padroniza os motivos de glosas, favorece a realização da justificativa do recurso, facilita a análise dos registros e auxilia no controle do pagamento do serviço prestado.

The impact of health information exchange on healthcare quality and cost-effectiveness: A systematic literature review.

BACKGROUND AND OBJECTIVE: Health Information Exchange (HIE) is known as a technology that electronically shares all clinical and administrative data throughout healthcare settings. Despite this technology has a great potential in the healthcare industry, there is a limited and sparse evidence of articles which illustrated the impact of HIE on quality of care and cost-effectiveness. This work presents a systematic review that evaluates the impact of HIE on quality and cost-effectiveness, and the rates of HIE adoption and participation in healthcare organizations. METHODS: We systematically searched all English papers that were indexed in four major databases (Science Direct, PubMed, IEEE and Web of Science) between 2005 and 2016. Consequently, 32 identified papers appeared in 21 international journals and conferences. Eligible studies independently were critically appraised, collected within data extraction form and then thematically analyzed by two reviewers and if necessary, the third author. The selected papers have been classified based on 11 main categories including publication year, journal and conference names, country and study design, types of data exchanged, healthcare levels, disease or disorder, participants in organizations and individuals, settings characteristics and HIE types, the impact of HIE on quality and cost-effectiveness, and the rates of HIE adoption and participation. RESULTS: Of the 32 articles, 25 studies investigated the financial and clinical impact of HIE. Overwhelmingly, HIE studies have reported positive findings for quality and cost-effectiveness of care. 15 of HIE studies (60%) demonstrated positive financial effects and 16 studies (64%) reported positive effects on quality improvement of patient care. However, the overall quality of the evidences was low. In this regard, cohort study (59.38%) was the most common used study design. Nine studies presented the rates of HIE adoption and participation. The lowest and highest participation rates were 15.7% and 79%, respectively. CONCLUSIONS: HIE can be considered as a superior potential for healthcare information system, resulting to promote patient care quality and reduce costs related to resource utilization. However, further researches are needed in order to provide a better understanding of this domain and accordingly attain new opportunities to increase users' participation and motivation for successfully adopting this technology.

The benefits of health information exchange: an updated systematic review.

Objective: Widespread health information exchange (HIE) is a national objective motivated by the promise of improved care and a reduction in costs. Previous reviews have found little rigorous evidence that HIE positively affects these anticipated benefits. However, early studies of HIE were methodologically limited. The purpose of the current study is to review the recent literature on the impact of HIE. Methods: We used the Preferred Reporting Items for Systematic Reviews and Meta-Analyses guidelines to conduct our systematic review. PubMed and Scopus databases were used to identify empirical articles that evaluated HIE in the context of a health care outcome. Results: Our search strategy identified 24 articles that included 63 individual analyses. The majority of the studies were from the United States representing 9 states; and about 40% of the included analyses occurred in a handful of HIEs from the state of New York. Seven of the 24 studies used designs suitable for causal inference and all reported some beneficial effect from HIE; none reported adverse effects. Conclusions: The current systematic review found that studies with more rigorous designs all reported benefits from HIE. Such benefits include fewer duplicated procedures, reduced imaging, lower costs, and improved patient safety. We also found that studies evaluating community HIEs were more likely to find benefits than studies that evaluated enterprise HIEs or vendor-mediated exchanges. Overall, these finding bode well for the HIEs ability to deliver on anticipated improvements in care delivery and reduction in costs.

E-health in Switzerland: The laborious adoption of the federal law on electronic health records (EHR) and health information exchange (HIE) networks.

Within the framework of a broader e-health strategy launched a decade ago, in 2015 Switzerland passed a new federal law on patients' electronic health records (EHR). The reform requires hospitals to adopt interoperable EHRs to facilitate data sharing and cooperation among healthcare providers, ultimately contributing to improvements in quality of care and efficiency in the health system. Adoption is voluntary for ambulatories and private practices, that may however be pushed towards EHRs by patients. The latter have complete discretion in the choice of the health information to share. Moreover, careful attention is given to data security issues. Despite good intentions, the high institutional and organisational fragmentation of the Swiss healthcare system, as well as the lack of full agreement with stakeholders on some critical points of the reform, slowed the process of adoption of the law. In particular, pilot projects made clear that the participation of ambulatories is doomed to be low unless appropriate incentives are put in place. Moreover, most stakeholders point at the strategy proposed to finance technical implementation and management of EHRs as a major drawback. After two years of intense preparatory work, the law entered into force in April 2017.

A strategic gaming model for health information exchange markets.

Current market conditions create incentives for some providers to exercise control over patient data in ways that unreasonably limit its availability and use. Here we develop a game theoretic model for estimating the willingness of healthcare organizations to join a health information exchange (HIE) network and demonstrate its use in HIE policy design. We formulated the model as a bi-level integer program. A quasi-Newton method is proposed to obtain a strategy Nash equilibrium. We applied our modeling and solution technique to 1,093,177 encounters for exchanging information over a 7.5-year period in 9 hospitals located within a three-county region in Florida. Under a set of assumptions, we found that a proposed federal penalty of up to $2,000,000 has a higher impact on increasing HIE adoption than current federal monetary incentives. Medium-sized hospitals were more reticent to adopt HIE than large-sized hospitals. In the presence of collusion among multiple hospitals to not adopt HIE, neither federal incentives nor proposed penalties increase hospitals' willingness to adopt. Hospitals' apathy toward HIE adoption may threaten the value of inter-connectivity even with federal incentives in place. Competition among hospitals, coupled with volume-based payment systems, creates no incentives for smaller hospitals to exchange data with competitors. Medium-sized hospitals need targeted actions (e.g., outside technological assistance, group purchasing arrangements) to mitigate market incentives to not adopt HIE. Strategic game theoretic models help to clarify HIE adoption decisions under market conditions at play in an extremely complex technology environment.

Enabling Health Reform through Regional Health Information Exchange: A Model Study from China.

Objective. To investigate and share the major challenges and experiences of building a regional health information exchange system in China in the context of health reform. Methods. This study used interviews, focus groups, a field study, and a literature review to collect insights and analyze data. The study examined Xinjin's approach to developing and implementing a health information exchange project, using exchange usage data for analysis. Results. Within three years and after spending approximately $2.4 million (15 million RMB), Xinjin County was able to build a complete, unified, and shared information system and many electronic health record components to integrate and manage health resources for 198 health institutions in its jurisdiction, thus becoming a model of regional health information exchange for facilitating health reform. Discussion. Costs, benefits, experiences, and lessons were discussed, and the unique characteristics of the Xinjin case and a comparison with US cases were analyzed. Conclusion. The Xinjin regional health information exchange system is different from most of the others due to its government-led, government-financed approach. Centralized and coordinated efforts played an important role in its operation. Regional health information exchange systems have been proven critical for meeting the global challenges of health reform.

Effect of health information exchange on recognition of medication discrepancies is interrupted when data charges are introduced: results of a cluster-randomized controlled trial.

OBJECTIVES: To determine the effect of health information exchange (HIE) on medication prescribing for hospital inpatients in a cluster-randomized controlled trial, and to examine the prescribing effect of availability of information from a large pharmacy insurance plan in a natural experiment. METHODS: Patients admitted to an urban hospital received structured medication reconciliation by an intervention pharmacist with (intervention) or without (control) access to a regional HIE. The HIE contained prescribing information from the largest hospitals and pharmacy insurance plan in the region for the first 10 months of the study, but only from the hospitals for the last 21 months, when data charges were imposed by the insurance plan. The primary endpoint was discrepancies between preadmission and inpatient medication regimens, and secondary endpoints included adverse drug events (ADEs) and proportions of rectified discrepancies. RESULTS: Overall, 186 and 195 patients were assigned to intervention and control, respectively. Patients were 60 years old on average and took a mean of 7 medications before admission. There was no difference between intervention and control in number of risk-weighted discrepancies (6.4 vs 5.8, P = .452), discrepancy-associated ADEs (0.102 vs 0.092 per admission, P = .964), or rectification of discrepancies (0.026 vs 0.036 per opportunity, P = .539). However, patients who received medication reconciliation with pharmacy insurance data available had more risk-weighted medication discrepancies identified than those who received usual care (8.0 vs 5.9, P = .038). DISCUSSION AND CONCLUSION: HIE may improve outcomes of medication reconciliation. Charging for access to medication information interrupts this effect. Efforts are needed to understand and increase prescribers' rectification of medication discrepancies.

Accountable care organization hospitals differ in health IT capabilities.

OBJECTIVES: The aim of this study was to evaluate health information technology (IT) adoption in hospitals participating in accountable care organizations (ACOs) and compare this adoption to non-ACO hospitals. STUDY DESIGN: A cross-sectional sample of US nonfederal, acute care hospitals with data from 3 matched sources: the 2013 American Hospital Association (AHA) Annual Survey, the 2013 AHA Survey of Care Systems and Payments (CSP), and the 2014 AHA Information Technology Supplement. METHODS: To compare health IT adoption in ACO- and non-ACO hospitals, we created measures of Meaningful Use (MU) Stage 1 and Stage 2 core and menu criteria, patient engagement-oriented health IT, and health information exchange (HIE) participation. Adoption was compared using both naïve and multivariate logit models. RESULTS: Of the 393 ACO hospitals and 810 non-ACO hospitals, a greater percentage of ACO hospitals were capable of meeting MU Stage 1 (50.9% vs 41.6%; P < .01) and Stage 2 (7.6% vs 4.8%; P < .05), having patient engagement health IT (39.8% vs 15.2%; P < .001), and participating in HIE (49.0% vs 30.1%; P < .001). In adjusted models, no difference was found between ACO and non-ACO hospital ability to meet MU Stage 1 or Stage 2, but ACO hospitals were more likely to have patient engagement health IT (odds ratio (OR), 2.20; 95% CI, 1.59-3.04) and be HIE participants (OR, 1.41; 95% CI, 1.03-1.92). CONCLUSIONS: ACO-participating hospitals appear to be focused more on adopting health IT that aligns with broader strategic goals rather than those that achieve MU. Aligning adoption with quality and payment reform may be a productive path forward to encourage hospital health IT adoption behavior.

The Number Of Health Information Exchange Efforts Is Declining, Leaving The Viability Of Broad Clinical Data Exchange Uncertain.

The diffusion of health information exchange (HIE), in which clinical data are electronically linked to patients in many different care settings, is a top priority for policy makers. To drive HIE, community and state efforts were federally funded to broadly engage providers in exchanging data in ways that improved patient care. To assess the current landscape, we conducted a national survey of community and state HIE efforts soon after federal funding ended. We found 106 operational HIE efforts that, as a group, engaged more than one-third of all US providers in 2014. However, the number of operational HIE efforts is down from 119 in 2012, representing the first decline observed since the tracking of these efforts began in 2006. Only half of operational efforts reported being financially viable, and all efforts reported a variety of barriers to continuation. These findings raise important questions about whether the current vision for HIE efforts will allow for the broad exchange of clinical data, or whether alternative approaches would be more successful.

Engagement In Hospital Health Information Exchange Is Associated With Vendor Marketplace Dominance.

Health information exchange (HIE) is intended to enable better, more efficient health care by electronically transferring patient data across provider organizations. Many policy makers, including members of Congress, are concerned that some electronic health record (EHR) vendors may be impeding this effort by making cross-vendor HIE difficult. We used national data to assess how market dominance by EHR vendors was related to hospitals' engagement in HIE in 2012 and 2013. Across all levels of vendor market dominance, hospitals using EHR systems supplied by the dominant vendor engaged in an average of 45 percent more HIE activities than hospitals not using the dominant vendor. However, when the dominant vendor controlled a small proportion-20 percent-of the market, hospitals using the dominant vendor engaged in 59 percent more HIE activities than hospitals using a different vendor. Conversely, when the dominant vendor controlled 80 percent of the market, hospitals using that vendor engaged in only 25 percent more HIE activities than hospitals using a different vendor. In markets with low vendor dominance, hospitals may engage in less HIE with hospitals using other vendors' systems, compared to markets with high vendor dominance, because of high costs and competitive barriers. Policies designed to promote cross-vendor HIE may need to take local market competition into account.

Exploring Business Strategy in Health Information Exchange Organizations.

Unlike consumer goods industries, healthcare has been slow to implement technolo gies that support exchange of data in patients' health records. This results in avoid able medication errors, avoidable hospital readmissions, unnecessary duplicate testing, and other inefficient or wasteful practices. Community-based regional health information exchange (HIE) organizations have evolved in response to federal aims to encourage interoperability, yet little is known about their strategic approach. We use the lens of institutional and strategic management theories to empirically explore the differences in business strategies deployed in HIEs that are, to date, financially sustainable versus those that are not. We developed a 20-question survey targeted to CEOs to assess HIE business strategies. Our sample consisted of 60 community-based exchanges distributed throughout the United States, and we achieved a 58% response rate. Questions centered on competitive strategy and financial sustainability. We relied on logistic regression methods to explore relationships between variables. Our regression identified characteristics common to sustainable organizations. We defined sustainability as revenues exceeding operational costs. Seventeen of the 35 organizations (49%) defined themselves as currently sustainable. Focus and cost leadership strategies were significantly associated with sustainability. Growth strate gies, which were much more common than other strategies, were not associated with sustainability. We saw little evidence of a differentiation strategy (i.e., the basis of competition whereby the attributes of a product or service are unmatched by rivals). Most CEOs had a relatively optimistic outlook, with 60% stating they were confident of surviving over the next 5 years; however, nearly 9% of the organizations were in some phase of divestiture or exit from the market. HIEs are evolving differently based on local leadership decisions, yet their strategic approach is isomorphic (or similar). Further insight into successful business strategies could help ensure the long-term survival of HIEs.

Cost Savings Associated with the Adoption of a Cloud Computing Data Transfer System for Trauma Patients.

INTRODUCTION: Among transferred trauma patients, challenges with the transfer of radiographic studies include problems loading or viewing the studies at the receiving hospitals, and problems manipulating, reconstructing, or evalu- ating the transferred images. Cloud-based image transfer systems may address some ofthese problems. METHODS: We reviewed the charts of patients trans- ferred during one year surrounding the adoption of a cloud computing data transfer system. We compared the rates of repeat imaging before (precloud) and af- ter (postcloud) the adoption of the cloud-based data transfer system. RESULTS: During the precloud period, 28 out of 100 patients required 90 repeat studies. With the cloud computing transfer system in place, three out of 134 patients required seven repeat films. CONCLUSION: There was a statistically significant decrease in the proportion of patients requiring repeat films (28% to 2.2%, P < .0001). Based on an annualized volume of 200 trauma patient transfers, the cost savings estimated using three methods of cost analysis, is between $30,272 and $192,453.

Health Information Exchange Readiness for Demonstrating Return on Investment and Quality of Care.

OBJECTIVE: To study the extent to which community health information exchanges (HIEs) deliver and measure return on investment (ROI) and improvements in the quality of care. MATERIALS AND METHODS: We surveyed operational HIEs for their characteristics, information domains, impact on quality of care, and ROI. RESULTS: A 60 percent response rate was achieved. Two-thirds of respondents agreed that community HIEs demonstrated a positive ROI, while one-third had no opinion or disagreed. One-fourth or fewer respondents reported using various metrics to calculate ROI. Most respondents agreed that HIEs improve the quality of care, though several were not sure and were awaiting further evidence. Most respondents indicated that they did not deliver reports on quality measures (76 percent) and that data were not being used to measure quality performance of participating providers (73 percent). DISCUSSION: Respondents from most HIEs believe that the HIEs are demonstrating a positive ROI; however, a minority of them indicated they had used or will use specific metrics to calculate ROI. HIE representatives overwhelmingly reported that they believe the HIE activities improve the quality of healthcare delivered, but only a few are using data to evaluate provider performance or generate reports on quality measures. CONCLUSION: This study demonstrates the challenge faced by policy makers and healthcare organizations that are investing millions of dollars in HIEs that are believed to improve health outcomes and increase efficiency, but still need more time to develop the evidence to confirm that belief. Our study shows that calculating ROI for HIEs or their impact on quality of care remains a secondary priority for most HIEs. This finding raises serious questions for the sustained support of HIEs, both financially and as a policy lever, given the end of Health Information Technology for Economic and Clinical Health (HITECH) Act funding.

Use of Health Information Exchange and Repeat Imaging Costs.

PURPOSE: The aim of this study was to quantify the association between health information exchange (HIE) use and cost savings attributable to repeat imaging. METHODS: Imaging procedures associated with HIE were compared with concurrent controls on the basis of propensity score matching over the period from 2009 to 2010 in a longitudinal cohort study. The study sample (n = 12,620) included patients ages 18 years and older enrolled in the two largest commercial health plans in a 13-county region of western New York State served by the Rochester Regional Health Information Organization. The primary outcome was a continuous measure of costs associated with repeat imaging. The determinant of interest, HIE use, was defined as system access after the initial imaging procedure and before repeat imaging. RESULTS: HIE use was associated with an overall estimated annual savings of $32,460 in avoided repeat imaging, or $2.57 per patient. Basic imaging (radiography, ultrasound, and mammography) accounted for 85% of the estimated avoided cases of repeat imaging. Advanced imaging (CT and MRI) accounted for 13% of avoided procedures but constituted half of the estimated savings (50%). CONCLUSIONS: HIE systems may reduce costs associated with repeat imaging. Although inexpensive imaging procedures constituted the largest proportion of avoided repeat imaging in our study, most of the estimated cost savings were due to small reductions in repeated advanced imaging procedures. HIE systems will need to be leveraged in ways that facilitate greater reductions in advanced imaging to achieve appreciable cost savings.

Health care provider perceptions of a query-based health information exchange: barriers and benefits.

BACKGROUND: Health information exchange (HIE) systems are implemented nationwide to integrate health information and facilitate communication among providers. The Nebraska Health Information Initiative is a state-wide HIE launched in 2009. OBJECTIVE: The purpose of this study was to conduct a comprehensive assessment of health care providers' perspectives on a query-based HIE, including barriers to adoption and important functionality for continued utilization. METHODS: We surveyed 5618 Nebraska health care providers in 2013. Reminder letters were sent 30 days after the initial mailing. RESULTS: A total of 615 questionnaires (11%) were completed. Of the 100 current users, 63 (63%) indicated satisfaction with HIE. The most common reasons for adoption among current or previous users of an HIE (N = 198) were improvement in patient care (N = 111, 56%) as well as receiving (N = 95, 48%) and sending information (N = 80, 40%) in the referral network. Cost (N = 233, 38%) and loss of productivity (N = 220, 36%) were indicated as the 'major barriers' to adoption by all respondents. Accessing a comprehensive patient medication list was identified as the most important feature of the HIE (N = 422, 69%). CONCLUSIONS: The cost of HIE access and workflow integration are significant concerns of health care providers. Additional resources to assist practices plan the integration of the HIE into a sustainable workflow may be required before widespread adoption occurs. The clinical information sought by providers must also be readily available for continued utilization. Query-based HIEs must ensure that medication history, laboratory results and other desired clinical information be present, or long-term utilization of the HIE is unlikely.

Health Information Exchange Capabilities in Skilled Nursing Facilities.

The purpose of this study is to determine the levels at which health information exchange is used by skilled nursing facilities for clinical functions, the benefits and barriers associated with health information exchange and telehealth/telemonitoring capabilities, and the facility characteristics associated with health information exchange capabilities. A cross-sectional design was implemented. Data were collected from nursing home administrators, using a mail and online survey approach. A total of 156 usable questionnaires were returned of 397 distributed­a 39.30% response rate. The highest level of electronic exchange for clinical functions was within the facility than within corporation/affiliated organization or with nonaffiliated providers. It was also more prevalent in for-profit skilled nursing facilities than nonprofit skilled nursing facilities. More than half of the facilities reported no electronic exchange for functions, such as public health reporting, diagnostic test orders/results, medical orders/e-prescribing, advance directives, lab orders/results, and radiology orders/ results. Similarly, telehealth/telemonitoring was not in wide use by facilities in the state. The greatest barriers to electronic exchange of clinical functions were financial barriers, technological barriers, and connectivity barriers. Faster and accurate billing, improved care planning, and improved quality of documentation were reported as benefits of electronic information exchange of clinical data with affiliated and nonaffiliated providers.