3. In 2014, hospitals will be penalized if their 30-day mortality rates for patients with heart attack, heart failure or pneumonia exceed expectations. But several commented they're worried the current risk adjustment methodologies for these measures is frail. Also, patients in the hospital to receive palliative end of life care are not excluded. "Hospitals that run large palliative care programs will have higher mortality rates," and penalizing them is inappropriate, Pollack wrote.
4. A huge issue in many letters deals with CMS' proposal to weight patient experience survey scores as 30% of the total. "Given the potential inadequacies of the risk adjustment, CMS should reduce the weight of the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) survey to at most 20% and conduct further research," said Premier Healthcare Alliance.
Wrote Anne Dykes of Monroe County Hospital, in Mobile, AL, "We do not agree that cleanliness of a hospital and quietness of hospital should be a combined question on HCAHPS."
5. A portion of the formula based on hospital spending per admission penalizes hospitals that care for more patients with chronic conditions, Adventist Health System's chief information officer Brent Snyder worries. "The larger cost issue is a coordination of resources to care for patients over multiple care settings, including the patient's home," he wrote, so VBP efficiency measures should be enforced through ACOs as well.
6. The provision that excludes hospitals that have been hit with an immediate jeopardy citation from participating in incentive payments under these rules is unfair because state programs differ dramatically in their aggressiveness in filing these penalties, several commenters complained.