Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
hold the provider in which a health-care associated
condition occurred liable for the cost of subsequent care
required to treat the condition.
Response: We appreciate the comments regarding MSP
policy and payment for health-care associated conditions in
downstream care settings. We look forward to further
exploring these issues with stakeholders.
Comment: A few commenters recognized that the HAC
payment provision targets a portion of an MS-DRG payment and
were unsure how this concept could be transferred to the
physician office setting. Further several commenters
mentioned bundled or global payment as a more rational way
to pay for Medicare services, which could obviate the need
for a healthcare-acquired condition payment provision.
Response: As commenters noted, the HAC payment
provision prohibits payment for a portion of the MS-DRG when
a HAC occurs in the inpatient setting. In that the HAC
payment provision results in payment being adjusted to a
lower level of payment, the basic payment concept could be
made applicable to other Medicare payment settings.
Implementation of such policies would likely depend on the
specific coding and payment systems used for each payment
system.
Comment: Several commenters expressed the need to
adjust for patient-specific factors like severity of illness
and patient compliance. A few commenters stated that unlike
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