"The current survey process in declaring an immediate jeopardy is extremely inconsistent from state to state, which could very well result in systematic biases between areas in the number of hospitals that receive citations and are excluded from the VBP program, wrote Pollack. (More on this in a future column.)
Premier Health Alliance wants CMS to not penalize hospitals that remediate an immediate jeopardy before their survey.
7. There are big problems with the three categories of measures due to kick in for 2014: measures for mortality, the Agency for Healthcare Research and Quality metrics such as having patients with post-operative respiratory failure, and hospital acquired conditions, the AHA's Pollack says. "The agency provides virtually no detail on how it proposes to score" hospitals performance," he says.
8. The proposed minimum of 10 cases a hospital must have to be included for certain metrics is too low, and is inconsistent with current requirements on Hospital Compare, which calls for at least 25, several organizations complained. "With less than that number the site (Hospital Compare) states that CMS cannot 'be sure how well a hospital is performing,' " Pollack wrote.
9. The regulations would allow CMS to have access to quality improvement organization information, which Pollack says would "strip many of the confidentiality safeguards and go against Congress' original intent in putting the confidentiality provisions in place."