"Just because overlapping hospital-acquired condition measures included in both the HAC Reduction Policy and Value-Based Purchasing programs have different scoring methodologies does not erase the facts CMS has tried to ignore: these programs are duplicative, with overlapping measures that penalize hospitals multiple times for the same HACs.
"For instance, under CMS' new policies, a single blood stream infection could count in two VBP measures, two HAC Reduction program measures and in the existing HAC policy. Penalizing providers five times for the same event is certainly not what Congress envisioned."
In the final rule, however, CMS remarked that it was not precluded by PPACA from using the same measure in multiple penalty programs.
"While we are aware that some commenters object to the possibility of scoring the CAUTI and CLABSI measures under both the Hospital VBP and HAC Reduction Programs, we note that these measures cover topics of critical importance to quality improvement in the inpatient hospital setting, and to patient safety.
"The NHSN (the CDC's National Healthcare Safety Network) measures that we have proposed to adopt track infections that could cause significant health risks to Medicare patients, and we believe it is appropriate to provide incentives for hospitals to avoid them under more than one program," CMS said.
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