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CMS-1403-FC
Response: We agree that a POA-type indicator would aid
in determining the onset of a healthcare-acquired condition.
We welcome the opportunity to work with stakeholders to
consider expansion of a POA-type indicator to all Medicare
settings of care. We look forward to working with entities
such as the National Uniform Billing Committee (NUBC) on the
implementation of a POA-type indicator for all settings of
care.
Comment: Many commenters identified attribution of a
healthcare-acquired condition to an individual physician who
is broadly managing the patient’s care as a challenge in
expanding the principle behind the HAC payment provision to
the physician office setting. Some commenters noted that
several physicians may be responsible for the care of a
patient, therefore attribution of the adverse event to
single physician may be difficult.
Response: We recognize that because health care is
delivered by a team of professionals, several providers
could potentially share responsibility for the occurrence of
a healthcare-associated condition. We have extensive
experience in testing various attribution methodologies in
our cost of care measurement initiative. We refer readers
to section III.C. of this final rule with comment period
(section 131(c) of the MIPPA) for further discussion of
attribution.
Comment: Some commenters expressed concern regarding
implementation of the Medicare secondary payer policy to
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