DPH presents first reports under Ordinance 077-22, highlights data gaps and plans to expand subacute capacity

The San Francisco Department of Public Health told the Health Commission on Tuesday that a newly enacted local ordinance requiring hospital reporting of skilled nursing and subacute transfers produced useful facility-level data but exposed major methodological differences that limit comparison across hospitals.

Claire Altman, senior health program planner, said Ordinance 077-22 compels general acute-care hospitals and hospital-based skilled nursing facilities to report the number of San Francisco residents (and nonresidents) who qualified for skilled nursing or subacute care and were either transferred out of county or remained in acute care. The reports for 2021 and 2022 showed substantial variation in how hospitals record transfers: some use discharge disposition codes, some rely on referral-management systems and several required manual chart review because "subacute" is not a standardized discharge code across EHRs.

That inconsistency, Altman said, meant the department could not aggregate or directly compare hospital counts across the city. "Because of the variety of methodologies that were used, our report for this year was limited, and hospitals' data could not be compared or it could not be aggregated," she told commissioners.

DPH staff walked the Commission through hospital-specific approaches: Chinese Hospital supplied in-county and out-of-county discharge data; Kaiser used a referral tool (CarePort) that includes a subacute code; Dignity used NaviHealth referral data but acknowledged possible double-counting; CPMC and UCSF reported gaps in address information that limited out-of-county identification; ZSFG used a "lower level of care" (LLOC) measure for patients who no longer required acute inpatient care.

Kelly Hiramoto, DPH special projects manager, described efforts to expand local subacute capacity. She said a 2022 RFP identified two sites for possible contract awards and that Chinese Hospital currently operates a 23-bed unit used for skilled-nursing overflow. "Chinese Hospital was also awarded $5,000,000 from the state to support renovating a unit to provide subacute care," Hiramoto said, adding that the renovation could add as many as 30 additional subacute beds once licensing and certification are complete.

Commissioners pressed staff for more detailed destination data (which counties or specific facilities patients are sent to) and asked whether families' preferences or proximity to relatives is being captured. Altman said hospitals often cited patient privacy and inconsistent recordkeeping as barriers but that DPH will continue working with reporting facilities to improve the dataset and to seek in-county transfer reporting in future cycles.

Public callers and some commissioners also questioned numerical differences reported across documents, including one caller who said a HSAG root-cause analysis listed 76 citations while DPH referenced 124 deficiencies for the same monitoring window; DPH acknowledged different reporting units and promised to provide clearer explanations of counts and definitions in future updates.

What happens next: DPH plans to continue refining methodology, consider administrative-day or LLOC metrics to better capture patients remaining in acute beds without acute needs, and return to the Commission with progress reports on Chinese Hospital certification and subacute bed operationalization.