The American Hospital Association has submitted comments to CMS in regard to the value-based purchasing component of the proposed 2012 hospital outpatient prospective payment system, saying "CMS has not met its requirements with respect to certain measures. This failure will unfairly and adversely impact the hospital field and even undermine the intent of the law," according to an AHA News Now report.
In a letter to CMS Administrator Donald Berwick, MD, the AHA contends that CMS' inpatient VBP rule fails to meet requirements outlined by the PPACA and "is exacerbated in the outpatient PPS rulemaking cycle because it builds on policies that fail to comply with the law's requirements."
Specifically, the AHA argues that a number of measures — including new Inpatient Quality Reporting measures included in VBP, hospital-acquired condition measures and AHRQ composite measures — were not made publicly available on Hospital Compare one year prior to the beginning of the performance period for the measure (as required by the PPACA) and therefore including them in the 2012 VBP program does not meet the law's requirements. As such, the AHA argues that these measures cannot be included in the 2012 VBP.
Additionally, the AHA takes issue with CMS' alleged failure to provide a specification document outlining how CMS arrived at the efficiency measure (Medicare spending per beneficiary) included in the VBP. According to the AHA, the specifications have not been made available one year in advance on Hospital Compare as required, and further, CMS has not taken the appropriate steps outlined in the PPACA to include measures not endorsed by the National Quality Forum.
In regards, to the outpatient VBP program, the AHA argues that because certain measures have still yet to be posted on Hospital Compare, the effective date of the VBP program needs to be pushed back in order to meet the one-year requirement. It also restated its opposition to including HAC measures in the VBP program because hospitals may be punished twice for higher-than-average HAC rates and urged CMS to reconsider weighting for its FY 2014 VBP measures.
What Value-Based Purchasing Will Mean for Hospitals, Other Providers
In a letter to CMS Administrator Donald Berwick, MD, the AHA contends that CMS' inpatient VBP rule fails to meet requirements outlined by the PPACA and "is exacerbated in the outpatient PPS rulemaking cycle because it builds on policies that fail to comply with the law's requirements."
Specifically, the AHA argues that a number of measures — including new Inpatient Quality Reporting measures included in VBP, hospital-acquired condition measures and AHRQ composite measures — were not made publicly available on Hospital Compare one year prior to the beginning of the performance period for the measure (as required by the PPACA) and therefore including them in the 2012 VBP program does not meet the law's requirements. As such, the AHA argues that these measures cannot be included in the 2012 VBP.
Additionally, the AHA takes issue with CMS' alleged failure to provide a specification document outlining how CMS arrived at the efficiency measure (Medicare spending per beneficiary) included in the VBP. According to the AHA, the specifications have not been made available one year in advance on Hospital Compare as required, and further, CMS has not taken the appropriate steps outlined in the PPACA to include measures not endorsed by the National Quality Forum.
In regards, to the outpatient VBP program, the AHA argues that because certain measures have still yet to be posted on Hospital Compare, the effective date of the VBP program needs to be pushed back in order to meet the one-year requirement. It also restated its opposition to including HAC measures in the VBP program because hospitals may be punished twice for higher-than-average HAC rates and urged CMS to reconsider weighting for its FY 2014 VBP measures.
Related Articles the VBP:
CMS' Value-Based Purchasing Forum: The Time is Now to Shift to Quality OutcomesWhat Value-Based Purchasing Will Mean for Hospitals, Other Providers