9. What are important elements of a Hospital VBP demonstration program to test innovative methods of measuring and rewarding quality and efficiency in Critical Access Hospitals, and hospitals with an insufficient number of cases or measures?
"Knowing that critical access hospitals rely very much on their relationship with hospitals to which they transfer, I think that measuring the accountability at the patient level in this process, so it's not just within the critical access hospital, would be a useful enhancement in terms of rewarding their ability to not only treat their own patients but also effectively and in a timely way triage their challenging patients to the referral centers. " Don Casey, Atlantic Health, Morristown, NJ.
10. What other considerations are essential to address in the development and implementation of a Hospital VBP program?
"We would urge CMS to consider when making VBP payment to consider making it in the form of a lump sum payment, for example [Perhaps pay] 80% of the hospital's estimated amount at the very beginning of the fiscal year. And then at the end, when the actual discharges are known, CMS could settle that amount. We think having a dedicated lump sum received by the hospital will help motivate them to improve their quality a little bit more." Joanna Kim with the American Hospital Association.)
CMS will review comments and concerns on the coming regulations if they are sent to HospitalVBP@cms.hhs.gov by Nov. 5.
The agency has a lot of work ahead to make sure the competition is a fair one. Yes, there will be winners and losers in this race, but let's hope that every hospital's performance will improve because of it. That, I think, was the idea from the start.