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CMS-1403-FC
maintenance of patient care quality (as opposed to the
improvement of patient care quality); [39] whether payments
should be permitted for the achievement of intermediate
targets for patient care quality and how intermediate
targets should be defined and measured; [40] what types of
medical evidence should support quality measures, and how
we can ensure that quality measures are supported by
credible medical evidence; and [41] whether measures must
have some relation to the patient populations and practices
at the hospital and, if so, what the relation should be,
and, if not, how we could protect against programs that are
structured to reward physicians for reaching subjective or
limited goals that do not substantially benefit the
hospital’s patients.
We seek additional information on how parties measure
patient care quality and determine appropriate payment
amounts for the achievement of targets for patient care
quality measures. For example, we request comments on:
[42] how quality improvement should be measured, including
how a baseline (that is, starting point) should be set from
which to measure the improvement, how recent the baseline
should be, and whether the targets should reflect regional
data, national data, or some other data; [43] whether we
should recognize a difference between “quality improvement”
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