ACO Update: Health Affairs Releases a Policy Brief

On January 31, 2012, Health Affairs, a peer-reviewed monthly journal, released a six page Health Policy Brief providing an update of where the US healthcare industry is in its rapid evolution towards accountable care type organizations.

The .pdf of the policy brief can be downloaded here.

The value of this paper is not limited to just the historical overview provided. The authors also give a general overview of some of the ongoing issues of the ACO model (small savings, anti-trust issues, enrollment, etc...).

Readers looking to for deep technical details of ACOs will be disappointed with this paper. However, those looking for a general overview of the current status of the ACO evolution will find this paper informative.

CMS Announces final details of Value Based Purchasing for Inpatient Acute Care

On April 29th, CMS announced the final rules of its upcoming Value Based Purchasing program for Inpatient Acute Care. This long anticipated program transitions the inpatient care provided to Medicare beneficaries from "pay for reporting" to "pay for performance".

The HHS press release itself is of little value to the healthcare quality professional. You can view it here: http://www.hhs.gov/news/press/2011pres/04/20110429a.html. However, it links to a CMS press release that contained more details. You can view it here: http://www.cms.gov/apps/media/press/factsheet.asp?Counter=3947.

Although these rules become effective with fiscal year 2013, CMS also released the list of measures for 2014 as well.

The following are excerpts from the CMS press release:


PERFORMANCE SCORING:

Performance Period: CMS has established a performance period that runs from July 1, 2011 through March 31, 2012, for the FY 2013 Hospital VBP payment determination. CMS anticipates that in future program years, if it becomes feasible, it may propose to use a full year as the performance period.

Scoring Methods: CMS will score each hospital based on achievement and improvement ranges for each applicable measure. A hospital’s score on each measure will be the higher of an achievement score in the performance period or an improvement score, which is determined by comparing the hospital’s score in the performance period with its score during a baseline period.

For scoring on achievement, hospitals will be measured based on how much their current performance differs from all other hospitals’ baseline period performance. Points will then be awarded based on the hospital’s performance compared to the threshold and benchmark scores for all hospitals. Points will only be awarded for achievement if the hospital’s performance during the performance period exceeds a minimum rate called the “threshold,” which is defined by CMS as the 50th percentile of hospital scores during the baseline period.

For scoring on improvement, hospitals will be assessed based on how much their current performance changes from their own baseline period performance. Points will then be awarded based on how much distance they cover between that baseline and the benchmark score. Points will only be awarded for improvement if the hospital’s performance improved from their performance during the baseline period.

Finally, CMS will calculate a Total Performance Score (TPS) for each hospital by combining the greater of its achievement or improvement points on each measure to determine a score for each domain, multiplying each domain score by the proposed domain weight and adding the weighted scores together. In FY 2013, the clinical process of care domain will be weighted at 70 percent and the patient experience of care domain will be weighted at 30 percent.

Incentive Payment Calculations: CMS will utilize a linear exchange function to calculate the percentage of value-based incentive payment earned by each hospital. Those hospitals that receive higher Total Performance Scores will receive higher incentive payments than those that receive lower Total Performance Scores. CMS will notify each hospital of the estimated amount of its value-based incentive payment for FY 2013 through its QualityNet account at least 60 days prior to Oct. 1, 2012. CMS will notify each hospital of the exact amount of its value-based incentive payment on Nov. 1, 2012.

FISCAL YEAR 2013 MEASURES

Clinical Process of Care Measures
AMI-7a - Fibrinolytic Therapy Received Within 30 Minutes of Hospital Arrival
AMI-8a - Primary PCI Received Within 90 Minutes of Hospital Arrival
HF-1 - Discharge Instructions
PN-3b - Blood Cultures Performed in the ED Prior to Initial Antibiotic Received in Hospital
PN-6 - Initial Antibiotic Selection for CAP in Immunocompetent Patient
SCIP-Inf-1 - Prophylactic Antibiotic Received Within One Hour Prior to Surgical Incision
SCIP-Inf-2 - Prophylactic Antibiotic Selection for Surgical Patients
SCIP-Inf-3 - Prophylactic Antibiotics Discontinued Within 24 Hours After Surgery End Time
SCIP-Inf-4 - Cardiac Surgery Patients with Controlled 6AM Postoperative Serum Glucose
SCIP-Card-2 - Surgery Patients on a Beta Blocker Prior to Arrival That Received a Beta Blocker During the Perioperative Period
SCIP-VTE-1 - Surgery Patients with Recommended Venous Thromboembolism Prophylaxis Ordered
SCIP-VTE-2 - Surgery Patients Who Received Appropriate Venous Thromboembolism Prophylaxis Within 24 Hours Prior to Surgery to 24 Hours After Surgery

Patient Experience of Care Measures (HCAHPS)
· Communication with Nurses
· Communication with Doctors
· Responsiveness of Hospital Staff
· Pain Management
· Communication About Medicines
· Cleanliness and Quietness of Hospital Environment
· Discharge Information
· Overall Rating of Hospital

ADDITIONAL MEASURES FINALIZED FOR FY2014

Mortality Measures:
· Mortality-30-AMI: Acute Myocardial Infarction (AMI) 30-day Mortality Rate
· Mortality-30-HF: Heart Failure (HF) 30-day Mortality Rate
· Mortality-30-PN: Pneumonia (PN) 30-Day Mortality Rate

Hospital Acquired Condition Measures:
· Foreign Object Retained After Surgery
· Air Embolism
· Blood Incompatibility
· Pressure Ulcer Stages III & IV
· Falls and Trauma: (Includes: Fracture, Dislocation, Intracranial Injury, Crushing Injury, Burn, Electric Shock)
· Vascular Catheter-Associated Infections
· Catheter-Associated Urinary Tract Infection (UTI)
· Manifestations of Poor Glycemic Control

AHRQ Patient Safety Indicators (PSIs), Inpatient Quality Indicators (IQIs), and Composite Measures:
· Complication/patient safety for selected indicators (composite)
· Mortality for selected medical conditions (composite)

Unadjusted "Fall and Trauma" Rates for Hospitals in Indiana

On April 6, 2011, CMS released a spreadsheet linked to its Hospital Compare website showing the frequency of the eight (8) Hospital Acquired Conditions (HAC) in hospitals participating in the Medicare Program. This data set is of Medicare beneficiaries only, is not risk adjusted for the severity of the patients, and is based on administrative data only for patients discharged between Oct 1, 2008 to June 30, 2010.

The data can be downloaded from CMS here.

The table below shows the performance of the listed Indiana hospitals for the "Fall and Trauma" measure sorted from high to low.

Hospital name	Rate (per 1,000 discharges)	Number of eligible discharges (Denominator)	Number of HACs (Numerator)	National HAC rate (per 1,000 discharges)
UNITY MEDICAL AND SURGICAL HOSPITAL	7.634	131	1	0.564
RIVERVIEW HOSPITAL	2.428	3707	9	0.564
THE HEART HOSPITAL AT DEACONESS GATEWAY LLC	1.878	1065	2	0.564
SAINT CATHERINE REGIONAL HOSPITAL	1.641	1219	2	0.564
FAYETTE REGIONAL HEALTH SYSTEM	1.553	1932	3	0.564
REID HOSPITAL & HEALTH CARE SERVICES	1.257	9549	12	0.564
FRANCISCAN PHYSICIANS HOSPITAL LLC	1.233	811	1	0.564
MEMORIAL HOSPITAL OF SOUTH BEND	1.205	9955	12	0.564
ST. CLARE MEDICAL CENTER	1.179	1697	2	0.564
WITHAM HEALTH SERVICES	1.174	1704	2	0.564
KOSCIUSKO COMMUNITY HOSPITAL	1.084	2767	3	0.564
PARKVIEW HUNTINGTON HOSPITAL	1.065	939	1	0.564
INDIANA UNIVERSITY HEALTH ARNETT HOSPITAL	1.02	4904	5	0.564
MARION GENERAL HOSPITAL	0.962	4158	4	0.564
HENRY COUNTY MEMORIAL HOSPITAL	0.957	3134	3	0.564
BLUFFTON REGIONAL MEDICAL CENTER	0.944	2118	2	0.564
CLARK MEMORIAL HOSPITAL	0.932	8581	8	0.564
INDIANA UNIVERSITY HEALTH NORTH HOSPITAL	0.906	3313	3	0.564
COMMUNITY HOSPITAL NORTH	0.9	6664	6	0.564
ST. FRANCIS HOSPITAL - BEECH GROVE	0.853	9377	8	0.564
THE ORTHOPAEDIC HOSPITAL	0.788	1269	1	0.564
ST. VINCENT CARMEL HOSPITAL, INC.	0.767	2609	2	0.564
ST. MARGARET MERCY - DYER	0.725	5515	4	0.564
WESTVIEW HOSPITAL	0.7	1429	1	0.564
INDIANA UNIVERSITY HEALTH WEST HOSPITAL	0.689	4352	3	0.564
ELKHART GENERAL HOSPITAL	0.676	8879	6	0.564
GOOD SAMARITAN HOSPITAL	0.641	6241	4	0.564
DEARBORN COUNTY HOSPITAL	0.617	3239	2	0.564
DUPONT HOSPITAL LLC	0.603	1658	1	0.564
BALL MEMORIAL HOSPITAL INC	0.591	11840	7	0.564
METHODIST HOSPITALS, INC	0.588	13602	8	0.564
ST. CATHERINE HOSPITAL, INC	0.576	5211	3	0.564
INDIANA ORTHOPAEDIC HOSPITAL LLC	0.565	1770	1	0.564
COMMUNITY HOSPITAL	0.557	16165	9	0.564
COMMUNITY HOSPITAL SOUTH, INC.	0.549	5468	3	0.564
SAINT ANTHONY MEDICAL CENTER	0.545	9179	5	0.564
SAINT JOSEPH REGIONAL MEDICAL CENTER - SOUTH BEND	0.541	11100	6	0.564
LUTHERAN HOSPITAL OF INDIANA	0.535	13088	7	0.564
INDIANA HEART HOSPITAL, THE	0.528	3791	2	0.564
ST. MARY'S MEDICAL CENTER OF EVANSVILLE INC	0.514	11672	6	0.564
GOSHEN GENERAL HOSPITAL	0.489	4088	2	0.564
PORTER HOSPITAL, LLC, VALPARAISO HOSP CAMPUS	0.481	10389	5	0.564
PARKVIEW HOSPITAL	0.465	10748	5	0.564
MAJOR HOSPITAL	0.457	2189	1	0.564
BLOOMINGTON HOSPITAL	0.445	8981	4	0.564
ST. FRANCIS HOSPITAL - MOORESVILLE	0.435	2299	1	0.564
DEACONESS HOSPITAL INC	0.422	18959	8	0.564
SCHNECK MEDICAL CENTER	0.421	2378	1	0.564
JOHNSON MEMORIAL HOSPITAL	0.421	2378	1	0.564
TERRE HAUTE REGIONAL HOSPITAL	0.411	4861	2	0.564
MEMORIAL HOSPITAL AND HEALTH CARE CENTER	0.385	5190	2	0.564
UNION HOSPITAL INC	0.383	13057	5	0.564
ST. JOSEPH HOSPITAL	0.381	2626	1	0.564
FLOYD MEMORIAL HOSPITAL AND HEALTH SERVICES	0.375	10678	4	0.564
WILLIAM N WISHARD MEMORIAL HOSPITAL	0.368	5431	2	0.564
ST. VINCENT HOSPITALS AND HEALTH SERVICES	0.358	19569	7	0.564
CLARIAN HEALTH PARTNERS, INCORPORATED	0.321	28027	9	0.564
ST. FRANCIS HOSPITAL - INDIANAPOLIS	0.313	6388	2	0.564
COLUMBUS REGIONAL HOSPITAL	0.296	6766	2	0.564
THE KING'S DAUGHTERS' HOSPITAL AND HEALTH SERVICES	0.28	3574	1	0.564
ST. ELIZABETH EAST	0.244	4090	1	0.564
COMMUNITY HOSPITAL EAST	0.244	8195	2	0.564
LA PORTE HOSPITAL AND HEALTH SERVICES	0.235	4263	1	0.564
ST. MARGARET MERCY HEALTHCARE CENTERS - HAMMOND	0.228	8754	2	0.564
ST. MARY MEDICAL CENTER, INC.	0.224	8912	2	0.564
ST. ELIZABETH CENTRAL	0.219	4558	1	0.564
COMMUNITY HOSPITAL OF ANDERSON AND MADISON COUNTY	0.179	5601	1	0.564
SAINT JOHN'S HEALTH SYSTEM	0.169	5918	1	0.564
SAINT ANTHONY MEMORIAL HEALTH CENTER	0	5335	0	0.564
KENTUCKIANA MEDICAL CENTER LLC	0	619	0	0.564
MEMORIAL HOSPITAL	0	1480	0	0.564
HENDRICKS REGIONAL HEALTH	0	3423	0	0.564
DAVIESS COMMUNITY HOSPITAL	0	1727	0	0.564
HOWARD REGIONAL HEALTH SYSTEM	0	4148	0	0.564
PHYSICIANS' MEDICAL CENTER LLC	0	180	0	0.564
SURGICAL HOSPITAL OF MUNSTER	0	31	0	0.564
ST. JOSEPH HOSPITAL & HEALTH CENTER, INC	0	3856	0	0.564
PINNACLE HOSPITAL	0	542	0	0.564
HANCOCK REGIONAL HOSPITAL	0	2989	0	0.564
MONROE HOSPITAL	0	1335	0	0.564
ST. VINCENT HEART CENTER OF INDIANA, LLC	0	5756	0	0.564
WOMEN'S HOSPITAL, THE	0	114	0	0.564
PARKVIEW WHITLEY HOSPITAL	0	807	0	0.564
STARKE MEMORIAL HOSPITAL	0	785	0	0.564
PARKVIEW NOBLE HOSPITAL	0	1175	0	0.564
SAINT JOSEPH REGIONAL MEDICAL CENTER - PLYMOUTH	0	1773	0	0.564
DEKALB MEMORIAL HOSPITAL INC	0	1100	0	0.564
MORGAN HOSPITAL AND MEDICAL CENTER	0	1472	0	0.564
ORTHOPAEDIC HOSPITAL AT PARKVIEW NORTH LLC	0	1039	0	0.564

CMS Proposes Value Based Purchasing Program Rules for Hospital Inpatient

On Friday, CMS announced its highly anticipated proposed rules for its new hospital value based purchasing program. The pdf of the proposed rules can be found here: http://www.ofr.gov/OFRUpload/OFRData/2011-00454_PI.pdf
(Note: this link will not likely become live until 1/13/2011).

Although these are "new" proposed rules, there are really no surprises in terms of payment methodology. The amount "at risk" due to poor performance is probably lower than what was initially expected (ie: 1-2% rather than 4-5%).


The following are excerpts from the CMS press release and fact sheet that may be of interest:

• Under the program, hospitals that perform well on quality measures relating both to clinical process of care and to patient experience of care, or those making improvements in their performance on those measures, would receive higher payments.
• The financial incentives would be funded by a reduction in the base operating DRG payments for each discharge, which under the statute will be 1% in FY 2013, rising to 2% by FY 2017.
• CMS will accept comments on the hospital value-based purchasing Program proposed rule until March 8, 2010, and will respond to them in a final rule to be issued next year.
• For the FY 2013 hospital value-based purchasing program, CMS proposes to use 17 clinical process of care measures as well as 8 measures from the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) survey that document patients’ experience of care.
• CMS also proposes to adopt three mortality outcome measures, eight Hospital Acquired Condition (HAC) measures, and nine Agency for Healthcare Research and Quality (AHRQ) measures for the FY 2014 Hospital VBP program.
• Proposed Performance Period: As required by the Affordable Care Act, CMS is proposing a performance period that ends prior to the beginning of FY 2013, specifically from July 1, 2011 through March 31, 2012, for the FY 2013 hospital value-based purchasing payment determination. CMS anticipates that in future fiscal years, the Agency may propose to use a full year as the performance period. In addition, CMS is proposing to use an 18-month performance period for the three proposed mortality measures for the FY 2014 Hospital VBP payment determination, and expects to propose a performance period for the eight HAC and nine AHRQ measures in future rulemaking.
• Proposed Scoring Methods: CMS proposes to score each hospital on relative achievement and improvement ranges for each applicable measure. A hospital’s performance on each quality measure would be evaluated based on the higher of an achievement score in the performance period or an improvement score, which is determined by comparing the hospital’s score in the performance period with its score during a baseline period of performance. For each of the proposed clinical process and patient experience of care measures that apply to a hospital for FY 2013, CMS proposes that a hospital would earn 0-10 points for achievement based on where its performance for the measure fell within an achievement range, which is a scale between an achievement threshold and a benchmark. With regard to the improvement score, CMS proposes that a hospital would earn 0-9 points based on how much its performance on the measure during the performance period improved from its performance on the measure during the baseline period. Finally, CMS would calculate a Total Performance Score (TPS) for each hospital by combining its scores on all of the measures within each domain, multiplying its performance score on each domain by the proposed weight for the domain, and adding the weighted scores for the domains.
• Proposed Incentive Payment Calculations:  CMS proposes to translate each hospital’s TPS into a value-based incentive payment using a linear exchange function.  The linear exchange function provides the same marginal incentives to both lower- and higher-performing hospitals.
• CMS proposes to notify each hospital of the estimated amount of its value-based incentive payment for FY 2013 through its QualityNet account at least 60 days prior to Oct. 1, 2012.  CMS proposes to notify each hospital of the exact amount of its value-based incentive payment on or about Nov. 1, 2012.
• CMS will accept public comments on the proposed rule through March 8, 2010  CMS will review all comments and respond to them in a final Hospital VBP rule scheduled to be released some time in 2011.

PROPOSED QUALITY MEASURES FY2013   
AMI-2: Aspirin Prescribed at Discharge
AMI-7a: Fibrinolytic Therapy Received Within 30 Minutes of Hospital Arrival
AMI-8a: Primary PCI Received Within 90 Minutes of Hospital Arrival
 
HF-1: Discharge Instructions
HF-2: Evaluation of LVS Function
HF-3: ACEI or ARB for LVSD

PN-2: Pneumococcal Vaccination
PN-3b: Blood Cultures Performed in the ED Prior to Initial Antibiotic Received in Hospital
PN-6: Initial Antibiotic Selection for CAP in Immunocompetent Patient
PN-7: Influenza Vaccination 
SCIP-Inf-1: Prophylactic Antibiotic Received Within One Hour Prior to Surgical Incision
SCIP-Inf-2: Prophylactic Antibiotic Selection for Surgical Patients
SCIP-Inf-3: Prophylactic Antibiotics Discontinued Within 24 Hours After Surgery End Time
SCIP-Inf-4: Cardiac Surgery Patients with Controlled 6AM Postoperative Serum Glucose
SCIP-Card-2: Surgery Pts. on a Beta Blocker Prior to Arrival... 
SCIP-VTE-1: Surgery Pts. with Recommended Venous Thromboembolism Prophylaxis Ordered
SCIP-VTE-2: Surgery Pts. Who Received Appropriate Venous Thromboembolism Prophylaxis...
 
HCAHPS: Communication with Nurses
HCAHPS: Communication with Doctors
HCAHPS: Responsiveness of Hospital Staff
HCAHPS: Pain Management
HACHPS: Communication About Medicines
HACHPS: Cleanliness and Quietness of Hospital Environment
HACHPS: Discharge Information
HACHPS: Overall Rating of Hospital

PROPOSED ADDITIONAL QUALITY MEASURES FOR FISCAL YEAR 2014

Mortality-30-AMI: Acute Myocardial Infarction (AMI) 30-day Mortality Rate
Mortality-30-HF: Heart Failure (HF) 30-day Mortality Rate
Mortality-30-PN: Pneumonia (PN) 30-Day Mortality Rate

Foreign Object Retained After Surgery
Air Embolism
Blood Incompatibility
Pressure Ulcer Stages III & IV
Falls and Trauma: (Includes: Fracture, Dislocation, Intracranial Injury, Crushing Injury, Burn, Electric Shock)
Vascular Catheter-Associated Infections
Catheter-Associated Urinary Tract Infection (UTI)
Manifestations of Poor Glycemic Control

PSI 06 – Iatrogenic pneumothorax, adult
PSI 11 – Post Operative Respiratory Failure
PSI 12 – Post Operative PE or DVT
PSI 14 – Post Operative would dehiscence
PSI 15 – Accidental puncture or laceration
IQI 11 – Abdominal aortic aneurysm (AAA) repair mortality rate (with or without volume)
IQI 19 – Hip fracture mortality rate

Complication/patient safety for selected indicators (composite)
Mortality for selected medical conditions (composite)

Berwick Testifies to the Senate Finance Committee

On November 17th, Donald Berwick testified before the Senate Finance Committee. As you can imagine, there was a lot of political tension surrounding this event.

The video of the entire senate hearing is here: http://finance.senate.gov/hearings/watch/?id=280ebc81-5056-a032-5254-1010c1e9b945

Berwick's prepared statement can be found here: http://finance.senate.gov/imo/media/doc/FINAL%20Donald%20Berwick%20Testimony%2011.15.101.pdf

Bacus' prepared opening statement can be found here: http://finance.senate.gov/imo/media/doc/11172010%20Baucus%20Hearing%20Statement%20Regarding%20New%20Patient%20Protections%20to%20Strengthen%20Medicare%20and%20Medicaid1.pdf

Grassley's prepared opening statement can be found here: http://finance.senate.gov/imo/media/doc/health%20care%2011-17-10%20hearing%20with%20Dr.pdf

Kaiser Health News, a program of the Kaiser Family Foundation, consolidated a resource page about Dr. Donald Berwick. It contains both what he has said as well as what others have said about him (and what he said). It can be found here: http://www.kaiserhealthnews.org/Stories/2010/June/30/Donald-Berwick-Resource-Guide.aspx

National Health Care Quality Strategy and Plan

The Secretary of the Department of Health and Human Services recently put out a call for public input on a national strategy for healthcare quality. You can see the document here.

The proposed framework of the national strategy centers around three principles: 1) Better Care; 2) Affordable Care; 3) Healthy People/Healthy Communities.

The specific questions that the HHS Secretary is asking the public are:

Question 1: Are the proposed Principles for the National Strategy appropriate? What is missing or how could the principles be better guides for the Framework, Priorities and Goals?

Question 2: Is the proposed Framework for the National Strategy sound and easily understood? Does the Framework set the right initial direction for the National Health Care Quality Strategy and Plan? How can it be improved?

Question 3: Using the legislative criteria for establishing national priorities, what national priorities do you think should be addressed in the initial National Health Care Quality Strategy and Plan in each of the following areas. Better Care: Person-centered care that works for patients and providers. Better care should expressly address the quality, safety, access, and reliability of how care is delivered and how patients rate their experience in receiving such care; Affordable Care: Care that reins in unsustainable costs for families, government, and the private sector to make it more affordable; and Healthy People/Healthy Communities: The promotion of health and wellness at all levels.

Question 4: What aspirational goals should be set for the next 5 years, and to what extent should achievable goals be identified for a shorter timeframe?

Question 5: Are there existing, well-established, and widely used measures that can be used or adapted to assess progress towards these goals? What measures would best guide public and private sector action, as well as support assessing the nation’s progress to meeting the goals in the National Quality Strategy?

Question 6: The success of the National Health Care Quality Strategy and Plan is, in large part, dependent on the ability of diverse stakeholders across both the public and private sectors to work together. Do you have recommendations on how key entities, sectors, or stakeholders can best be engaged to drive progress based on the National Health Care Quality Strategy and Plan?

Question 7: Given the role that States can play in organizing health care delivery for vulnerable populations, do the Principles and Framework address the needs and issues of these populations?

Question 8: Are there priorities and goals that should be considered to specifically address State needs?

Question 9: What measures or measure sets should be considered to reflect States’ activities, priorities, and concerns?

Question 10: What are some key recommendations on how to engage with States and ensure continued alignment with the National Quality Strategy?

The deadline for public submission is October 15, 2010 at 5pm. The HHS has created a convenient website for feedback submission at: http://www.hhs.gov/news/reports/quality/nhcqsap.html

CMS to inspect 1/3 of all Ambulatory Surgery Centers this Year Regarding Infection Prevention Practices

In a press release from HHS Secretary Kathleen Sebelius on June 8, a clear signal was sent to ambulatory surgery centers that they will be receiving additional attention from CMS regarding their infection prevention and control practices.

The press release is cut and pasted here. Sections of interest to the healthcare quality professional are highlighted in red.


FOR IMMEDIATE RELEASE
Tuesday, June 8, 2010
Contact: HHS Press Office
(202) 690-6343


HHS Secretary Kathleen Sebelius Statement on Recent Study of Infection Control Practices in Ambulatory Surgical Centers

“Today, the Journal of the American Medical Association published a new study from the Centers for Disease Control and Prevention (CDC) and the Centers for Medicare & Medicaid Services (CMS), which underscored the urgency behind the Obama Administration’s efforts to reduce healthcare-associated infections (HAIs).

The study found that among a sample of ambulatory surgical centers (ASCs) in three states, two-thirds had infection control lapses identified during routine inspections. This is concerning, because when lapses in infection control occur, in any healthcare setting, it puts patients at risk.

The good news is that we have seen progress in the reduction of HAIs in the hospital setting. Just last month, a new report from CDC demonstrated progress made in reducing HAIs in hospitals, further indicating that the steps we’re taking to reduce these often preventable infections are working. The report showed an 18-percent decrease in national central-line associated bloodstream infection incidence in hospitalized patients.

Ensuring the safety of all patients in all healthcare settings is a top priority for HHS. That’s why I announced last year that $50 million of American Recovery and Reinvestment Act funds to help states fight HAIs. Of that funding, $10 million went to states to improve the process and increase the frequency of inspections for ambulatory surgical centers.

In addition, the Affordable Care Act calls for improvements in healthcare quality and HAIs. Research shows that when healthcare facilities identify where and when infections are likely to occur and take concrete steps to prevent them, some infection rates have dropped more than 70 percent in hospitals.

We also continue to strengthen our collaborative efforts to achieve the goals in the HHS Action Plan to Prevent Healthcare-Associated Infections (http://www.hhs.gov/ophs/initiatives/hai/). In 2010, HHS will expand its Action Plan to include strategies to eliminate HAIs in ambulatory surgical centers and hemodialysis centers.

HHS’ Agency for Healthcare Research and Quality (AHRQ) is contributing to the reduction of infections in ASCs by investing in research projects to better understand the factors that lead to HAIs in ambulatory surgical settings. HHS agencies are also working together to incorporate infection control into the inspection process. CMS has committed to inspecting one-third of all ASCs nationwide this year. All ASCs have a responsibility to correct deficient practices. Failing to correct serious deficiencies will mean the risk of termination from the Medicare program.

Just because procedures are being performed outside the hospital doesn’t mean patient safety standards and attention to infection control do not need to be met. All healthcare providers and suppliers should take this as an opportunity to evaluate their current infection control policies, and more importantly, make sure their staff understand and follow them.”

To view the infection control audit tool currently used by CMS to better assess infection control practices in ambulatory surgical centers, please visit: http://www.cms.gov/manuals/downloads/som107_exhibit_351.pdf

New RAC Rules for Document Request Limits

Yesterday, CMS updated its rules regarding limits on the number of additional documentation requests. Excerpts from the document has been cut and pasted below.

You can download the original document at:http://www.cms.hhs.gov/RAC/Downloads/DRGvalidationADRlimitforFY2010.pdf

You can find the RAC homepage at: http://www.cms.hhs.gov/RAC/


Additional Documentation Limits for FY 2010 for DRG Validation
as of December 1, 2009 (Excerpts)

• CMS has modified the additional documentation request limits for the RAC program in FY 2010. These limits will be set by each RAC (CMS) on an annual basis to establish a cap per campus on the maximum number of medical records that may be requested per 45-day period.
• A campus unit (defined below) may consist of one or more separate facilities/practices under a single organizational umbrella; each limit will be based on that unit’s prior fiscal year Medicare claims volume.
• Limits will be based on the servicing provider/supplier’s Tax Identification Number (TIN) and the first three positions of the ZIP code where they are physically located.
• Limits will be set at 1% of all claims submitted for the previous calendar year (2008), divided into eight periods (45 days). Although the RACs may go more than 45 days between record requests, in no case shall they make requests more frequently than every 45 days. A provider’s limit will be applied across all claim types, including professional services. Note: FY 2010 limits are based on submitted claims, irrespective of paid/denied status and/or individual lines, although interim/final bills and RAPs/final claims shall be considered as a unit.
• While respecting a provider’s overall limit, the RAC may exercise discretion in the exact composition of an additional documentation request. For example, the RAC may request inpatient records up to the full limit even though the provider’s inpatient business may only be a small portion of their total claim volume.
• Two caps will exist in FY 2010: Through March 2010, the cap will remain at 200 additional documentation requests per 45 days for all providers/suppliers. However, from April through September 2010, providers/suppliers who bill in excess of 100,000 claims to Medicare (per TIN, across all claims processing contractors) will have a cap of 300 additional documentation requests per campus unit, per 45 days.
• In addition, in FY 2010 CMS will allow the RACs to request permission to exceed the cap. Permission to exceed the cap cannot be requested in the first six (6) months of the fiscal year. The expanded cap will not be automatic; the RACs must request approval from CMS on a case-by-case basis and affected providers will be notified prior to receiving additional requests.

Healthy People 2020 - Review Draft Objectives

Early last week the US Dept of Health and Human Services released the draft Healthy People 2020 objectives for public comments via the internet.

Historically, federal agencies have been guided somewhat by the objectives set in Healthy People. Every 10 years, the objectives are developed, reviewed, updated, and/or archived.

You can download the draft objectives here: http://www.healthypeople.gov/hp2020/Objectives/files/Draft2009Objectives.pdf

Or,...you can go to the following webpage to review the objectives and comment directly:
http://www.healthypeople.gov/hp2020/Objectives/TopicAreas.aspx

Note that Healthcare IT and Hospital Aquired Infections are established objectives in Healthy People 2020.

The entire press release from the AHRQ is below:

Opportunity for public comment on draft Healthy People 2020 objectives

The U.S. Department of Health and Human Services invites you to comment on the DRAFT set of objectives for Healthy People 2020. For three decades, Healthy People has provided a set of national 10-year health promotion and disease prevention objectives aimed at improving the health of all Americans.

Visit www.healthypeople.gov/hp2020 to
· View proposed draft objectives for Healthy People 2020
· Comment on the proposed objectives
· Comment on the topic areas
· Suggest additional objectives
· Suggest topic areas you feel are missing from the draft set

Your comments will help ensure issues important to you are included in Healthy People. Establishing objectives and providing benchmarks to track progress motivates, guides, and focuses action. Be part of the change. Comments will be accepted through December 31, 2009.

Visit www.healthypeople.gov/hp2020 today. Your feedback will help define the vision and strategy for building a healthier Nation.