6. What are some of the unintended consequences that might result from implementing this hospital pay-for-performance program? How should CMS monitor the impact of the program on beneficiaries and the health care system?
"One unintended consequence will come if CMS shies away from introducing outcomes measures as core principles in VBP. One reason there might be some shyness is that there are no perfect outcome measures that absolutly everyone agrees are 100% indicative of the actual performance of a provider. If we let the ‘perfect’ substitute for the ‘good’, we will, in fact, not create a VBP that has enough teeth to make a difference either for providers or for consumers." Leah Binder, CEO, Leapfrog Group.
The proposal is (that) 60 days in advance, facilities would receive notification of potential losses based on performance. We would argue that even prior to that if there could be some advance warning system or ongoing tracking...that could give administrators [We would hope that CMS could] "give a prior notification or early warning or tracking ... that would give administrators and hospitals a heads up as far as what current performance means and subsequent losses. The unintended consequences could create knee jerk reactions based on losses, or not give enough financial planning for organizations that would suffer the most severe losses." Jessica Walker, the Gallup Organization.
7. What validation processes should be included in the Hospital VBP?
"[Electronic medical records] systems have not lived in the world of quality performance measurement. And often times, or at least right now, lack the rigor required of these calculations of complex algorithms and Boolean statements that are inherent in these specifications...I would urge to transition cautiously to the world of measures to the world of value-based purchasing until we fully understand this new world." Name unclear.
8. What appeals process should be included in the Hospital VBP?
"We would request that you consider not publishing results under appeals until appeals have been resolved and perhaps allow hospitals a chance to comment or protest if you decide to publicly publish before the issues are resolved."—Barney Osborne, vice president for finance for the South Carolina Hospital Association.