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

Cheryl Clark, for HealthLeaders Media , March 10, 2011

"Everything You Know Is Wrong!" the title of an album by the comic troupe Firesign Theatre, came to mind this week as I reviewed the state of chaos that stymies progress in healthcare quality.

The Senate may not confirm Don Berwick as administrator for the Centers for Medicare and Medicaid Services. Anticipated CMS regulations governing accountable care organizations are held up, reportedly because the Federal Trade Commission sees a lethal anti-trust flaw. And the entire Affordable Care Act has been declared unconstitutional by a Florida court, although the Obama administration is asking for a speedy decision to its appeal.

If all these obstructions aren't enough to befuddle providers, I wandered into the comments section of CMS' regulations.gov yesterday to find nearly 300 postings on the agency's proposed regulations governing Hospital Inpatient Value Based Purchasing (VBP) penalties (the deadline for filing comments was 11:59 p.m. Tuesday).  

I took a sample of 32 comments and found vehement objections to various aspects of the formula that directs how hospitals will soon be paid. I wondered, how did the process get this far along with so many major players still finding so much to oppose?

Perhaps the most detailed dissection of the regulations' perceived unfairness came from American Hospital Association executive vice president Rick Pollack, who wrote a nearly 10,000-word letter with strong protests on nearly every one of its 20 pages.

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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.




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