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10 Ways CMS's Value-Based Purchasing Proposal is Flawed

Cheryl Clark, for HealthLeaders Media, March 10, 2011

"The current survey process in declaring an immediate jeopardy is extremely inconsistent from state to state, which could very well result in systematic biases between areas in the number of hospitals that receive citations and are excluded from the VBP program, wrote Pollack. (More on this in a future  column.)

Premier Health Alliance wants CMS to not penalize hospitals that remediate an immediate jeopardy before their survey.

7. There are big problems with the three categories of measures due to kick in for 2014: measures for mortality, the Agency for Healthcare Research and Quality metrics such as having patients with post-operative respiratory failure, and hospital acquired conditions, the AHA's Pollack says. "The agency provides virtually no detail on how it proposes to score" hospitals performance," he says.

8. The proposed minimum of 10 cases a hospital must have to be included for certain metrics is too low, and is inconsistent with current requirements on Hospital Compare, which calls for at least 25, several organizations complained. "With less than that number the site (Hospital Compare) states that CMS cannot 'be sure how well a hospital is performing,' " Pollack wrote.

9. The regulations would allow CMS to have access to quality improvement organization information, which Pollack says would "strip many of the confidentiality safeguards and go against Congress' original intent in putting the confidentiality provisions in place."

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1 comments on "10 Ways CMS's Value-Based Purchasing Proposal is Flawed"


Leah Binder (3/16/2011 at 5:55 PM)
I have worked alongside hospital professionals for over 20 years, and maintain enormous respect for these leaders who dedicate their lives to caring for our families when we are at our most vulnerable. As a parent and daughter, it comforts me profoundly to think of the exceptional people I have known who are there for us in American hospitals. That is why I call on my colleagues in hospitals to take leadership in advancing needed changes in health care, to show through the courage and candor that they will stand up first for the patients who entrust their lives in their care. In that spirit, let me propose [INVALID]native commentary hospitals might use with regard to AHA's Top 10 list. 1) Re: Topped out measures[INVALID]Eliminate process measures like "aspirin at arrival" because most hospitals are close to 100% and should be held accountable for the outcomes of our care to our patients, not for following recipes for delivering that care. 2) Re: Hospital-acquired conditions[INVALID]Hospitals are deeply embarrassed that study after study shows that HACs are common in hospitals, such as the recent Office of the Inspector General report suggesting one in four Medicare beneficiaries is harmed in some way by an inpatient stay. The strongest possible financial and other incentives need to be exercised to reduce this problem, because these events can be catastrophic to patients, and patients must come first. 3) Re: Not penalizing hospitals for 30-day mortality rates: Hospitals should be held accountable for their mortality rates, so patients can make decisions about which hospital to choose. There will never be a perfect measure, but mortality rate is so critical to patients and clinicians that we must quickly disseminate this information to the public using the best measures we have. 4) Re: Patient experience scores: Patients must come first, so their experience should be weighted heavily in payments to hospitals. We have some issues with HCAHPs, but for now it's the best we have and should be used immediately to factor in patient experience when considering payments to hospitals. We will work to develop even more robust ways of measuring patient experience, such as real time devices that allow patients to report via cellphone or other device on their level of pain, satisfaction, etc. 5) Re: Hospital spending per admission: Health costs in the US are unsustainable and it's urgent for our economy and our children's future that we hold hospitals more directly accountable. ACOs and other provider arrangements should be held accountable as well. 6) Re: Immediate jeopardy citations: Laws and regulations are often not enforced uniformly, but a hospital cited for immediate jeopardy should not be eligible for preferred payments from CMS. This is a matter of earning the public trust. 7) Performance measure detail: Hospitals stand ready to hold themselves accountable to the highest possible standards for safety and quality, and we will contribute our expertise and energy toward identifying measures to accomplish this. 8) Minimum of 10 cases: Statisticians may argue over a good minimum, but let's go as low as possible, because people who live in rural areas deserve the same high quality of care as people who live in urban areas. 9) QIOs: Patient protection must come first. 10) Safety net standards: Many outstanding safety net hospitals perform at the highest levels of quality and safety. It is harder for them to do so, and we commend them.