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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.
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