As “Accountability: The Fast Lane on the Highway to Change” points
out, public health accreditation appears to be similar to a train with a
strong head of steam. The train’s destination of improving population
health by improving public health management is laudable. The arguments
behind holding local public health departments accountable with
accreditation are that it will improve population health, that marginal
benefits outweigh marginal costs and that undesirable unintended
consequences can be mitigated. The logic model is that accountability will
result in improved population health (1, 2). Since accreditation strongly
focuses on the essential services functions rather than content, the
implicit argument is that performing the essential service functions well
are a sufficient cause of improved population health. This accreditation
effect presumably occurs either because (a) accreditation leads to
enhanced legitimacy which leads to resource acquisition which supports
performance of content activities, such as those related to achieving
Healthy People 2010 goals (3), or (b) accreditation leads to better
performance of content activities. The improved implementation of content
activities presumably results in improved population health. The causal
mechanism implication is that content activities mediate between
legitimacy, the essential services functions and population health. The
over emphasis on functions to the neglect of content may result in
accreditation not having its desire effects.
The over emphasis on functions to the exclusion of content may make
reaching accreditation goals more difficult and may be harmful to
achieving these goals. While the difficulty with specifying accreditation
standards in terms of content is understandable (4), did the pendulum
swing too far towards functions? This note raises questions about whether
accreditation with a strong focus on functions is the best method for
creating effective accountability for local health departments. This note
raises six distinct issues, the: (1) difficulty of emphasizing function
over content; (2) lack of evidence base for accreditation; (3) costs and
benefits of accreditation; (4) unintended consequences of accreditation;
(5) weakly acknowledged contribution of related health professionals; and
(6) local health department economics.
First, accreditation’s functional emphasis emerged from the
difficulty in agreeing on content standards (4) and Handler, Issel and
Turnock on core functions (5). This important work for implementing the
essential public standards for health and organizing communities provides
guidance for developing effective management. But, this has not been
balanced by an emphasis on content – what public health does for
communities. In comments about the proposed accreditation standards
submitted to the Public Health Accreditation Board, the Minnesota
Department of Health had the same concern(6): “Currently, most measures
are process measures. In the long term, quality improvement efforts should
demonstrate not only process improvement, but should also be linked to
public health goals and overall improvements in population health
outcomes.” Professions gain legitimacy by effectively addressing content –
by improving outcomes. In fact, it is likely that professions with
effective programs, such as reducing STDs or teen pregnancies, are more
likely to garner support from funders than professions that simply
demonstrate they can perform functions. The emphasis on functions may
also be harmful because professionalization theory argues that professions
emphasizing functional knowledge to the exclusion of content are likely to
be weak professions (7).
Second, in this day of evidence based management, it seems reasonable
to expect that accountability is based on good evidence. To date, we have
little or weak evidence that establishes a causal link between
accreditation and population health outcomes. As Beitsch et al. state “A
painful truth separating public health from other scientific endeavors is
the relative dearth of evidence supporting what actually works in the
field.”(8) Having good evidence is important because as a recent New York
Times article on diabetes care pointed out, inappropriate use of
guidelines and standards can be harmful (9). The lack of evidence in
public health is in part due to the variety of causes of public health
outcomes which weakens the relationship between functions and outcomes.
It would seem the best way to develop evidence would be to show how
functions are implemented effectively in content activities in specific
health domains. This would allow an evidence base to be developed so that
accreditation would meet the same standard as those desired for public
health activities – that it be evidence based. Furthermore, it will be
probably much more difficult to develop strong, useful evidence about the
relationship between functions and population health than it will be to
develop evidence on how functions are related to content activities and
then to population health in specific health domains. Adding an
accountability focus on content may make easier the development of a
strong evidence base.
Third, an argument for accreditation is that benefits exceed costs
(10). Costs can be classified into four categories based on whether they
are start-up or ongoing and direct or opportunity. Heany et al. suggest
that most direct costs will be labor costs and that start-up costs will be
significantly greater than operating costs(10). They point out that these
costs will be a function of context. Meit et al., for example, suggest
that rural health departments may face significant human resource and
financial barriers to accreditation(11). There are also opportunity costs.
The benefits are presumably better performance of content activities.
Unfortunately, in contrast to other types of health care organizations,
accreditation may not result in access to greater funds. Opportunity costs
occur because while staff is involved in accreditation functions, either
as start-up or ongoing, some of their efforts on content related work must
be curtailed. If “public health is tasked too much while resourced too
little,”(8) then both the start-up and ongoing opportunity costs can pose
significant risk.
Fourth, there are likely to be unintended consequences. The old
saying, “we manage to what we measure” reveals a potential unintended
consequence. Measuring functions rather than content risks over-allocating
resources to functions rather than content, such as health education, WIC,
MCH, immunizations, STD testing, or environmental safety. As well as
reducing the amount of content related efforts, the emphasis on functions
risks demoralizing staff because it takes them away from the work that
drew them to public health in the first place. Accreditation efforts may
distract health departments from identifying and addressing local health
concerns. Finally it may result in wasting financial resources.
Assessment, for example, is an important function. But, how much
assessment is enough assessment? The answer to this is content specific.
The neglect of content in accreditation standards may result in the
resource misallocation.
Fifth, it is hard to discern from reading the accreditation standards
that allied professions, such as environmental health specialists, health
educators, or public health nurses, provide essential public health
contributions. These professions are key contributors to content
activities. Among other activities, public health nurses contribute to
mass immunization preparedness exercises and engage in direct contact with
the public through service delivery activities. These activities build
trust between the health department and the local community which
facilitates collaboration. It also provides public health situational
awareness, the real-time assessment of emerging public health issues in
the community. Given the importance of these professions to doing public
health, it would seem reasonable that a key dimension of accountability is
making sure that local health departments have a work force that has the
knowledge, skills, and ability necessary to do public health rather than
just manage public health.
Ironically, accreditation’s focus on functionality means that the
accreditation cannot even hold a local health department accountable for
the essential service of assuring a competent public and personal health
workforce. Without knowing what services need to be provided, the content
of public health, how do we know a local health department is staffed with
individuals who have the necessary knowledge, skills, and ability to do
those activities?
Sixth, the accreditation standards gloss over local public health
department economics. Many health departments generate revenue from
services, such as immunizations, STD testing, the WIC program, and
environmental health inspections. While we understand that these are not
population services, these services generate important revenue streams and
legitimacy. They help health departments reach scale economies so that
support staff, such as grant writers, grant managers, and individuals who
are capable of doing assessment, can be employed. These services are
visible and valued products in the community that build local health
department legitimacy. If service delivery provides some of the financial
foundation for implementing the essential services and increases
legitimacy, it seems reasonable to recognize that contribution. Ignoring
the health department economics may result in not “every community (no
matter how small or remote)”(4) being able to meet the proposed
accreditation standards. Is the accreditation process meeting the
accountability goals it set for itself for inclusion of all communities?
We have raised a number of questions about the current accreditation
and accountability approach. We agree with the goal of improving
population health and increasing health department capability. We
disagree with the emphasis on functionality to the exclusion of other
important issues. We argue that accreditation should also take into
account (a) content of specific activities, (b) costs and benefits, (c)
unintended consequences, (d), the important contributions of allied
professions, and (e) the economics of health departments.
An alternative to the current accreditation may be using a quality
improvement approach, such as that recommended for health departments and
by developing evidence about the use of essential services by specific
content (health domain). It may get us to the desired goals of better
public health organization and improved population health outcomes more
quickly and effectively than the current approach. As Robert Pestronck,
NACCHO’s Executive Director, commented at the 2009 Keeneland Conference on
Public Health Systems, improving public health organization is a long term
project. Going more slowly and carefully will allow the development of a
meaningful evidence-base that is health domain and context sensitive and
is more likely to produce useful knowledge for public health managers. It
will also minimize the risk of marginalizing public health that may occur
when functionality is over-emphasized rather than balanced with content.
REFERENCES
1. Corso LCW, Paul J. Halverson, Paul K. Brown, Carol K. Using the
Essential Services as a Foundation for Performance Measurement and
Assessment of Local Public Health Systems. Journal of Public Health
Management & Practice 2000;6(5):1.
2. Joly BM, Polyak G, Davis MV, Brewster J, Tremain B, Raevsky C, et al.
Linking accreditation and public health outcomes: a logic model approach.
J Public Health Manag Pract 2007;13(4):349-56.
3. Beitsch LM, Corso LC. Accountability: The Fast Lane on the Highway to
Change. American Journal of Public Health 2009:AJPH.2009.172957.
4. Tilson HH. Public Health Accreditation: Progress on National
Accountability. Annual Review of Public Health 2008;29(1).
5. Handler A, Issel M, Turnock B. A Conceptual Framework to Measure
Performance of the Public Health System. 2001;91(8):1235-1239.
6. Minnesota Department of Health. National Public Health Standards for
State Health Departments, Summary of Recommendations from the Spring, 2009
Vetting Process, Submitted to the Public Health Accreditation Board. In.
St. Paul, MN: Minnesota Department of Health; 2009.
7. Abbott A. The System of Professions: An Essay on the Division of Labor.
Chicago: The University of Chicago Press; 1988.
8. Beitsch LM, Mays G, Corso L, Chang C, Brewer R. States gathering
momentum: Promising strategies for accreditation and assessment activities
in multistate learning collaborative applicant states. Journal of Public
Health Management and Practice 2007;13(4):364-373.
9. Meier B. Diabetes Case Shows Pitfalls of Treatment Rules New York Times
2009 August 18, 2009
10. Heany J, Laing S, Austin J, Blackinton P, Sherry MK, Martin A.
Quantifying the Cost of Accreditation in Local Public Health. In: Academy
Health. Okemos, MI: Michigan Public Health Institute, Center for
Healthcare Excellence; 2009.
11. Meit M, Harris K, Bushar J, Piya B, Molfino M. Challenges,
Opportunities, and Stratgies for Rural Public Health Agencies Seeking
Accreditation. Chicago, IL: NORC: Walsh Center for Rural Health Analysis;
2008.