Notice: This CMS-approved document has been submitted - Philips ...
Notice: This CMS-approved document has been submitted - Philips ... Notice: This CMS-approved document has been submitted - Philips ...
CMS-1403-FC requiring the provider that failed to prevent the occurrence of a preventable condition in one setting to pay for all or part of the necessary follow up care in a second setting. This would help shield the Medicare program from inappropriately paying for the downstream effects of a reasonably preventable condition acquired in the first setting but treated in the second setting. We note that we did not propose new Medicare policy in this discussion of the possible application of the HAC payment policy for IPPS hospitals to other settings, as some of these approaches may require new statutory authority. Instead of proposing policy, we solicited public comment on the application of the preventable HAC payment provision for IPPS hospitals to other Medicare payment systems. We also stated that we look forward to working with stakeholders in the fight against all healthcare-associated conditions. The following is a summary of the comments we received and our responses. Comment: Commenters recommended that CMS work with technical experts, such as physicians and hospitals, to determine the impact, burden, and accuracy of POA indicator reporting in the inpatient setting before it is expanded to other settings of care. Commenters specifically recommended 198
CMS-1403-FC that CMS consider issues of adverse selection and access to care for vulnerable populations. Many commenters had concerns with CMS’ authority and ability to implement such a policy for the physician office setting. Response: We agree that the HAC payment provision should be studied to determine its impact. We also recognize the importance of aligning VBP policy across all Medicare payment systems. We believe it is appropriate to consider policies of not paying more for medical care that harms patients or leads to complications that could have been prevented. For example, we note that CMS is currently considering National Coverage Determinations (NCDs) for three of the National Quality Forum’s Serious Reportable Events: (1) surgery on the wrong body part, (2) surgery on the wrong patient, and (3) wrong surgery performed on a patient. NCDs can address physician services as well as institutional services. We will work with stakeholders as we move forward in combating healthcare-associated conditions in all Medicare payment settings. Any additional policies, within statutory authority, addressing these issues would be proposed through notice and comment rulemaking. Comment: Some commenters stated that CMS may need to implement a Present on Admission (POA)-type indicator to recognize healthcare-acquired conditions in the physician office and ESRD settings of care, similar to the IPPS POA indicator. 199
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<strong>CMS</strong>-1403-FC<br />
requiring the provider that failed to prevent the<br />
occurrence of a preventable condition in one setting to pay<br />
for all or part of the necessary follow up care in a second<br />
setting. <strong>This</strong> would help shield the Medicare program from<br />
inappropriately paying for the downstream effects of a<br />
reasonably preventable condition acquired in the first<br />
setting but treated in the second setting.<br />
We note that we did not propose new Medicare policy in<br />
this discussion of the possible application of the HAC<br />
payment policy for IPPS hospitals to other settings, as<br />
some of these approaches may require new statutory<br />
authority. Instead of proposing policy, we solicited<br />
public comment on the application of the preventable HAC<br />
payment provision for IPPS hospitals to other Medicare<br />
payment systems. We also stated that we look forward to<br />
working with stakeholders in the fight against all<br />
healthcare-associated conditions.<br />
The following is a summary of the comments we received<br />
and our responses.<br />
Comment: Commenters recommended that <strong>CMS</strong> work with<br />
technical experts, such as physicians and hospitals, to<br />
determine the impact, burden, and accuracy of POA indicator<br />
reporting in the inpatient setting before it is expanded to<br />
other settings of care. Commenters specifically recommended<br />
198