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

Cheryl Clark, for HealthLeaders Media , March 10, 2011

Wrote Stacie Neff of Clallam County Hospital District in Washington State, "Before CMS gives/sells CMS performance data to outside vendors/researchers, we would want rigorous assurances and safeguards to ensure our patient’s privacy and confidentiality."

10. Safety net hospitals can't be judged by the same standards as the typical American hospital, Ellen Kugler, executive director of the National Association of Urban Hospitals, wrote . The VBP regulations assume that in an emergency room, "physicians can make a swift, clear, and specific diagnosis." This is challenging when patients in low-income, urban safety net hospitals are fundamentally sicker, with years of neglect and with co-conditions that mask or are more prominent than an underlying condition associated with a specific quality measure, she wrote.

There were a lot more objections in these letters, but more on that in later columns.

Though many of the comments on the CMS website were negative, not all were. Here's one from Vivian Lauderdale of Encinitas, CA.

"Dear CMS: I am a grandmother, mother, health technology professional and have had a personal experience with harmful healthcare events.  Please record my full support of the proposed rule ... because it can have enormous impact on our healthcare due to the fact that hospitals will only be paid if they are accountable for safety improvement. ...There may be many special interest groups that oppose this rule; however, I believe that the data or measures do not need to be perfect to move the motivations of America's healthcare leaders and caregivers to improving care in this country."

After reading these comments and watching the state of paralysis and disagreement in which healthcare providers seem to find themselves in right now, another favorite line from Firesign's repertoire springs to mind:

"How can you be in two places at once when you're not anywhere at all." In my humble opinion, we should all move forward with healthcare reform and fix problems along the way. As the saying goes, let not the perfect be the enemy of the good.

To read more about what providers and others think about CMS' VBP regs, visit regulations.gov and search "Comments" with the keyword CMS-2011-0003

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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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