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<strong>CMS</strong>-1403-FC<br />

the inpatient setting, the physician office setting does not<br />

lend itself to close monitoring of patient compliance.<br />

Response: We recognize that certain beneficiaries may<br />

pose a greater risk of contracting a healthcare-acquired<br />

condition. We also note that providers must carefully<br />

consider those risk factors to avoid preventable conditions.<br />

We refer readers to the FY 2009 Inpatient Prospective<br />

Payment System final rule (73 FR 48487 through 48488<br />

(http://edocket.access.gpo.gov/2008/pdf/E8-17914.pdf) where<br />

we discussed risk-adjustment as a potential enhancement to<br />

the IPPS HAC provision.<br />

Comment: Many commenters believe that it could be more<br />

effective to combat healthcare-acquired conditions by<br />

adjusting payments based on a provider’s rates of<br />

healthcare-associated conditions rather than to directly<br />

adjust the payment for an individual service.<br />

Response: We agree that capturing rates of healthcare-<br />

associated conditions and using those rates for performance-<br />

based payment may be a more sophisticated and effective way<br />

to adjust payment. Rates of healthcare-associated<br />

conditions may be good candidates as possible quality<br />

measures for VBP programs like the PQRI as discussed in more<br />

detail in section II.O. of this final rule with comment<br />

period. Further, the ESRD pay-for-performance program and<br />

the forthcoming Physician VBP Plan Report to Congress may<br />

also address healthcare-associated conditions.<br />

202

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