Additionally, the group said it has "serious concerns about specific components of the plan, such as the inclusion of hospital-acquired conditions in the VBP program, the weighting of the patient experiences of care survey data, and the required minimum number of patient cases to participate in the program."
For example, the AHA said that the decision to weight patient experiences of care at 30% could result in hospitals being "systematically biased against performing well on these measures. Until that refinement occurs, the HCAHPS measures should receive less weight."
Additionally, the AHA said it "strongly opposes the inclusion of HAC measures in both the VBP program and the future HAC penalties provision because of the opportunity for hospitals to be penalized twice on the same measures and we are disappointed that CMS included them in the final rule."
CMS also refused to accept the AHA's recommendation that a minimum of 25 cases on any value-based measurement be required for that hospital to be included. But CMS held on to the language in its proposed rule, that hospitals with fewer than 10 cases would be excluded. "We are disappointed that CMS did not follow our recommendation."