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

CMS-1403-FC
associated with the hospital, because hospital personnel
and medical staff physicians are intimately aware of
hospital operations and patient populations.
We seek comments on [11] whether, assuming that there
is a need for independent medical review, the need would be
greater if the exception were to include outcome measures
that are not on the CMS-approved list. We also seek
comments on an alternative to independent medical review
that would provide an objective, accurate and complete
review. Specifically, we request comments addressing [12]
how, if no independent medical review is required, we could
ensure that a hospital is objective in the review of its
incentive payment and shared savings program, that programs
operate appropriately to improve (or maintain) patient care
quality, and that the incentive payment or shared savings
program results in no diminution of patient care quality or
inappropriate reduction in care. Finally, and irrespective
of whether we would require independent medical review or
permit “in-house” review, we seek comments on: [13] how,
when and what type of (for example, further review,
corrective action, or termination of the incentive payment
or shared savings program) recommendations should be made
by the reviewer when the program review identifies concerns
with patient care quality or the diminution in patient care
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