According to the American Hospital Association (AHA), the Centers for Medicare & Medicaid Services (CMS) has thus far failed to report certain measures of the complex value-based purchasing (VBP) program – a reality that might not only undermine the law but ultimately make it harder for hospitals to engage VBP for performance improvements.
"Despite the law's specificity, CMS has not met its requirements with respect to certain measures," AHA's letter states. AHA lists those metrics as Medicare spending per beneficiary, hospital acquired conditions, and the AHRQ composite measures.
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AHA continues that the impact of CMS' failure to meet the measures leaves hospitals without a clear definition of which cases are included, full details of how the measures are to be calculate, or the opportunity to examine a year's worth of data to understand each measure's effect and potential unintended consequences, and how measures are risk-adjusted.
Particular to the Medicare spending per beneficiary measure, AHA describes the impact of CMS not reporting results as leaving hospitals without the opportunity to review their own performance to that regard, or to request changes or attest to calculated measures' accuracy.
AHA's letter also gave voice to concerns about the timing of the performance periods, how CMS handled the comments period, domain weighting and not sharing results from the Brandeis and Mathematica analyses, as well as the review and corrections process for VBP.
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Taken together, the points AHA highlighted in its letter ultimately make it harder for hospitals to transition to VBP and, in turn, render the VBP model less effective than it ought to be.
"This failure will unfairly and adversely impact the hospital field and even undermine the intent of the law," AHA's letter states, "which is to provide opportunities for hospitals to improve their performance."