AB 1204 Hospital Equity Reporting Support (HCAI Equity Report Compliance)

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HQI Support for California’s Hospital Equity Reporting Requirements

California’s AB 1204 (Medical Equity Disclosure Act) requires hospitals to submit an annual Hospital Equity Report to the California Department of Health Care Access and Information (HCAI).

The report requires hospitals to:

  • Calculate core quality measures stratified by demographic factors such as race/ethnicity, age, sex, payor, and language
  • Identify the Top 10 disparities within those measures
  • Develop an Equity Plan describing actions to address those disparities
  • Submit the report to HCAI and post the report on the hospital’s website

Reports cover the previous calendar year (January 1–December 31) and are due to HCAI September 30 each year.

Because the reporting format is a complex CSV-based data submission with thousands of fields, most hospitals find it difficult to produce the required calculations and formatting internally. Our platform allows hospitals to leverage existing administrative data and validated analytics to generate the majority of the required report fields automatically, significantly reducing the technical burden on hospital staff.

The Hospital Quality Institute (HQI) has developed tools within the Hospital Quality Improvement Platform (HQIP) to help hospitals generate AB 1204–compliant reports using existing administrative data.

Hospitals remain responsible for submitting their final report to HCAI through the HDC submission portal and posting the report on their website as required by state regulations.

Which Hospitals are Required to Report?

2024 List of Required Hospitals for Hospital Equity Report Submission – No Update Yet


HQI’s AB 1204 Equity Reporting Solution

HQI’s solution leverages data already available in the HQIP analytics platform to produce a near-complete Hospital Equity Report.

For participating hospitals, HQIP:

  • Generates most report fields automatically as data permit (typically about 95% of the required report fields)
  • Calculates required core quality measures
  • Applies required stratifications
  • Identifies the Top 10 Disparities
  • Generates an HCAI-formatted CSV report
  • Provides an interactive Equity Dashboard to help hospitals develop their Equity Plan

Hospitals primarily focus on completing the 33–38 User Input fields that are not automatically populated by HQIP, particularly the narrative Equity Plan and the descriptions of hospital performance across six priority areas.

Click “Field Coverage Marix” below to open a detailed PDF reference table showing which AB 1204 measures, stratifications, and report fields are generated by HQIP for hospital and system Equity Reports.

AB 1204 Hospital Equity Report Field Coverage Matrix – 2026 Update


Equity Dashboard & Disparity Analysis

The HQIP Equity Dashboard provides an interactive environment for exploring disparities and validating the Top 10 disparities included in the report.

The dashboard allows hospitals to:

  • Review calculated disparities and rate ratios
  • Compare stratified outcomes across demographic groups
  • Analyze trends over time
  • Evaluate community and population impact

These analytics help hospital teams develop the Equity Plan portion of the AB 1204 report, which describes strategies for reducing disparities across priority areas such as patient safety, access to care, care coordination, and effective treatment.

The next AB 1204 reporting cycle is now underway. Hospitals should begin preparing CY2025 administrative encounter data so disparities and equity reports can be generated in time for the September 30 submission deadline.


Data Requirements for HQI Report Generation

To generate the Equity Dashboard and Top 10 disparities for the 2026 AB 1204 reports, HQI requires hospitals to provide complete CY2025 administrative encounter data in the same format submitted to HCAI.

Depending on facility type, this typically includes:

  • Inpatient discharge data
  • Emergency Department encounter data
  • Ambulatory surgery encounter data

These files must match the original submission format used for HCAI reporting.

Important Note on SIERA Data Downloads

  • Hospitals sometimes download data from SIERA after making corrections.
  • However, these downloaded files typically exclude Social Security Numbers (SSNs).
  • HQIP uses the same hashed patient-linkage identifiers contained in the original SIERA submission files to track patients across encounters when calculating 30-day readmissions.
  • Because SSNs are required for tracking patients across encounters, missing SSNs prevent HQIP from correctly calculating 30-day readmissions.
  • In most cases, this issue can be resolved if hospitals still retain the original files submitted to SIERA, which contain the SSNs. Those identifiers can usually be restored before uploading to HQIP.

Compatibility with CMQCC Maternal Data

Many California hospitals already participate in the California Maternal Quality Care Collaborative (CMQCC) and generate maternal quality reports through the CMQCC Maternal Data Center (MDC).

HQI collaborates with CMQCC to ensure that maternal measure files generated in the MDC can be uploaded directly into the HQIP equity reporting workflow.

Hospitals upload the MDC-generated maternal measure files (not raw maternity encounter extracts) into HQIP to incorporate maternity measures into the Equity Report and Top 10 analysis.

This approach helps hospitals avoid duplicate data preparation and ensures that maternal equity metrics remain consistent with CMQCC reporting.

Hospitals with questions about CMQCC maternal data files should contact the CMQCC Maternal Data Center (MDC) Team:

datacenter@cmqcc.org


Questions or Participation

If your hospital would like assistance generating an AB 1204 Equity Report using HQIP, or if you have questions about data preparation or report generation, please contact the HQI Analytics Team:

hqianalytics@hqinstitute.org


*** Updates for 2026 ***

** Regulatory Developments **

HCAI has recently issued proposed regulatory updates to the Hospital Equity Reporting Program.

Hospitals wishing to provide feedback can contact:

Trina Gonzalez
Vice President, Public Policy
California Hospital Association
tgonzalez@calhospital.org
916-552-7543

Written comments are due April 7, 2026.

HQI’s analytics team is actively monitoring these regulatory developments because changes may require updates to:

  • Report calculations
  • Stratification logic
  • Dashboard outputs
  • Final report formatting
  • Report field definitions and CSV column headers

** Smoother Process **

The second year of AB 1204 reporting will be similar to the first, but we expect it to be much smoother.

Hospitals, regulators, and HQI all have a much better understanding of:

  • The reporting requirements
  • The analytics involved
  • HCAI’s expectations for report submissions

With improved tools, better workflows, and lessons learned from the first year, we are optimistic that the 2026 reporting cycle will be significantly easier for participating hospitals.


** Participation and Contracts **

Most hospitals that participated in HQI’s AB 1204 reporting support during the first reporting cycle signed rolling contracts, which continue into the 2026 reporting year.

If you are unsure whether your hospital’s agreement is still active, please contact us and we will confirm.


** Platform Improvements for the 2026 Reporting Cycle **

Based on lessons learned during the first reporting year and subsequent audits, several improvements have been made to the HQIP equity reporting workflow.

* Automatic SDOH Cell Suppression *

SDOH and structural measure values entered by hospitals in the User Input Fields now also receive cell suppression consistent with the California Health and Human Services Data De-Identification Guidelines (DDG) when the final report is generated.

Additional validation checks may also be applied during report generation.

* Addressing “Creeping Top 10s” *

Hospitals reported challenges with Top 10 disparities changing over time as more complete data were uploaded to HQIP (particularly with readmissions).

HQI is currently working on a universal solution to stabilize Top 10 disparities, though final implementation is still under evaluation.

Until a stabilization approach is finalized, hospitals should expect Top 10 disparities to be most stable after complete CY2025 data have been uploaded and validated.


** Reporting Timeline Considerations **

The AB 1204 reporting cycle depends heavily on the availability of complete HCAI data submissions.

Hospitals are required to submit CY2025 inpatient and encounter data to HCAI through March 31, 2026, and facilities frequently revise earlier submissions before that deadline.

Because of this, HQI cannot generate final disparities or Top 10 analyses until the full reporting year is complete and hospitals have finalized their HCAI submissions.

In addition, HCAI has proposed regulatory revisions to the Hospital Equity Reporting Program that may affect report calculations, field definitions, and submission formatting.

HQI will begin updating the HQIP equity reporting workflow once:

  • the March 31 HCAI data submission deadline has passed, and
  • the regulatory changes are finalized.

Once these conditions are met, HQI will update the platform, regenerate analytics, and release updated dashboards and reports for hospital review prior to the September 30 submission deadline.


** Biweekly Workgroups & Platform Development **

HQI plans to resume its biweekly hospital AB 1204 workgroup meetings once both (1) CY2025 data submissions are complete and available for upload into HQIP and (2) required platform updates driven by the proposed regulatory revisions have been implemented.

Based on current timelines, HQI expects platform updates and analytics improvements to be completed by late June or early July, allowing hospitals sufficient time to review results and finalize their reports before the September 30 submission deadline.


HQI Guidance & Templates


HCAI Guidance & Documentation


Demos, Accounts, Questions, & Tech Support

Contact the HQI Analytics Team at: HQIAnalytics@HQInstitute.org

Platform Link: https://hqipanalytics.org