The Medicare spending per beneficiary measure, the hospital-acquired conditions measure, the composite measures defined by the Agency for Healthcare Research and Quality and planned outcomes of care domains such as 30-day mortality all must be delayed until FY 2014 to satisfy ACA provisions, Pollack wrote.
6. The ability of hospitals to review and validate measures and data is lacking, he wrote. "Beyond explicitly creating an appeals process, hospitals should be afforded the opportunity to pursue an external validation of the measures that CMS calculates.
The AHA urges "CMS to make available a database including all of the data used to calculate the hospital VBP measures. CMS must provide the data in a format that is consistent with the time periods used for the baseline and performance data. Until this resource is made available, hospitals have not been given the right of appeal that was afforded in the ACA."