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 the inpatient setting, the physician office setting does not lend itself to close monitoring of patient compliance. Response: We recognize that certain beneficiaries may pose a greater risk of contracting a healthcare-acquired condition. We also note that providers must carefully consider those risk factors to avoid preventable conditions. We refer readers to the FY 2009 Inpatient Prospective Payment System final rule (73 FR 48487 through 48488 (http://edocket.access.gpo.gov/2008/pdf/E8-17914.pdf) where we discussed risk-adjustment as a potential enhancement to the IPPS HAC provision. Comment: Many commenters believe that it could be more effective to combat healthcare-acquired conditions by adjusting payments based on a provider’s rates of healthcare-associated conditions rather than to directly adjust the payment for an individual service. Response: We agree that capturing rates of healthcare- associated conditions and using those rates for performance- based payment may be a more sophisticated and effective way to adjust payment. Rates of healthcare-associated conditions may be good candidates as possible quality measures for VBP programs like the PQRI as discussed in more detail in section II.O. of this final rule with comment period. Further, the ESRD pay-for-performance program and the forthcoming Physician VBP Plan Report to Congress may also address healthcare-associated conditions. 202
CMS-1403-FC Comment: Commenters raised concern regarding the use of financial incentives to combat healthcare-associated conditions. Many commenters suggested that CMS should encourage compliance with evidence-based guidelines rather than use direct payment adjustments to address healthcare-associated conditions in the physician office setting. Response: We agree that it is important for Medicare providers to provide care that is consistent with evidence-based guidelines. We intend to consider all of our statutory and regulatory authorities, including the implementation of quality measures and payment adjustments, to encourage provision of care that is consistent with evidence-based guidelines. We look forward to working with stakeholders to further identify and apply available methods to combat healthcare-acquired conditions. Comment: Many commenters supported the alignment of incentives across all Medicare settings of care. Response: We appreciate the public’s support of our efforts to align incentives across all Medicare payment settings. We look forward to working with stakeholders to expand VBP initiatives in all Medicare payment settings. Further, we intend to host a public listening session toward the end of CY 2008 to discuss the expansion of the HAC payment provision, specifically targeting both the inpatient and hospital outpatient department (HOPD) settings of care. 203
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<strong>CMS</strong>-1403-FC<br />
Comment: Commenters raised concern regarding the use<br />
of financial incentives to combat healthcare-associated<br />
conditions. Many commenters suggested that <strong>CMS</strong> should<br />
encourage compliance with evidence-based guidelines rather<br />
than use direct payment adjustments to address<br />
healthcare-associated conditions in the physician office<br />
setting.<br />
Response: We agree that it is important for Medicare<br />
providers to provide care that is consistent with<br />
evidence-based guidelines. We intend to consider all of our<br />
statutory and regulatory authorities, including the<br />
implementation of quality measures and payment adjustments,<br />
to encourage provision of care that is consistent with<br />
evidence-based guidelines. We look forward to working with<br />
stakeholders to further identify and apply available methods<br />
to combat healthcare-acquired conditions.<br />
Comment: Many commenters supported the alignment of<br />
incentives across all Medicare settings of care.<br />
Response: We appreciate the public’s support of our<br />
efforts to align incentives across all Medicare payment<br />
settings. We look forward to working with stakeholders to<br />
expand VBP initiatives in all Medicare payment settings.<br />
Further, we intend to host a public listening session toward<br />
the end of CY 2008 to discuss the expansion of the HAC<br />
payment provision, specifically targeting both the inpatient<br />
and hospital outpatient department (HOPD) settings of care.<br />
203