The ratio of observed-to-expected deaths is considered a measure of hospital quality and for this reason will soon become a basis for payment. However, there are drivers of that metric more potent than quality: most important are medical documentation and patient acuity. If hositals underdocument and therefore do not capture the full “expected mortality” they may be tempted to lower their observed/expected ratio by reducing “observed mortality” through limiting access to the very ill. Underdocumentation occurs because hospitals do not recognize, and therefore cannot seek to confirm, specific comorbidities conferring high mortality risk. To help hospitals identify these comorbidities, this paper describes an easily implemented spread-sheet for evaluating comorbid conditions associated, in any particular hospital, with each discharge. This method identifies comorbidities that increase in frequency as mortality risk increases within each diagnostic grouping. The method is inductive and therefore independent of any particular risk-adjustment technique.