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Comment Letter to CMS on Hospital Outpatient Prospective Payment System and Calendar Year 2009 Payment Rates; Proposed Rule
Finance and Reimbursement
Last Updated: 8/28/2008
August 28, 2008
Kerry Weems, Acting Administrator
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201
RE: CMS-1404-P, Medicare: Hospital Outpatient Prospective Payment System and Calendar Year 2009 Payment Rates; Proposed Rule
Dear Mr. Weems:
On behalf of our more than 225 member hospitals and health care systems, The Hospital & Healthsystem Association of Pennsylvania (HAP) welcomes this opportunity to comment on the proposed rule, “Medicare: Hospital Outpatient Prospective Payment System (OPPS) and Calendar Year 2009 Payment Rates; Proposed Rule” as published in the July 18, 2008, Federal Register.
The Centers for Medicare & Medicaid Services (CMS) has proposed significant changes to the Medicare OPPS and, while the proposed rule has many components, there are three key areas within the rule that significantly will impact Pennsylvania hospitals and health systems. The key components of the proposed rule include:
- Outpatient Outlier Reconciliation
- Hospital Outpatient Quality Measures—2009 and beyond
- Healthcare-Associated Conditions
The following are summary comments on the key issues mentioned above.
Outpatient Outlier Reconciliation
HAP has concerns in the proposed rule with respect to CMS setting the reconciliation thresholds manually, and CMS has not clearly defined the acceptable percent change and outlier dollar amount involved. Due to the fact that manual changes are not subject to public comment, we believe CMS should clarify more precisely the threshold in terms of what would trigger a need for reconciliation.
Hospital Outpatient Quality Measures
HAP is concerned that the measures implemented for 2009 have never been fully field tested for hospital outpatient reporting. As a consequence, hospitals are beginning to identify a series of technical issues that were not anticipated, and therefore not answered, in advance of the required hospital reporting. HAP has learned of concerns about the measures not being specified in such a way as to allow hospitals to unambiguously identify the relevant patient population and collect the data accordingly. Therefore, HAP remains concerned that the data that are collected and reported will not present an “apples to apples” comparison of quality. HAP strongly recommends that CMS fully field test the surgical care and heart attack transfer patient care outpatient measures to identify operational issues and determine whether identified problems can be addressed before data validation on the CY 2009 measures begins. Additionally, HAP recommends that CMS adequately fund the infrastructure required for outpatient measure reporting, including the resources required by the Florida Quality Improvement Organization (QIO) to provide the appropriate level of technical assistance to hospitals across the country.
With respect to the imaging efficiency measures that CMS proposes to be collected and tied to the 2010 annual OPPS payment update, HAP believes that CMS should table consideration of these measures until the National Quality Forum has fully evaluated and endorsed the measures and the Hospital Quality Alliance (HQA) has considered whether they are important and appropriate measures to include in a public report card on hospital quality. Further, HAP is concerned about the lack of sufficient detail on the measures in the proposed rule in the Federal Register, which made it very difficult to offer informed comments as to the merits of the measures with respect to quality and quality improvement.
Healthcare-Associated Conditions
CMS is seeking comment on whether and how the Medicare Inpatient Prospective Payment System (IPPS) policy of not paying more for preventable healthcare-associated conditions could be applied to the hospital outpatient department setting. HAP cautions CMS against expanding the healthcare-associated conditions policy to any other settings or providers until CMS has the opportunity to analyze the effects of implementing the policy in the inpatient hospital setting. Further, making any such changes to the OPPS would require congressional action.
HAP has enclosed more detailed comments on other sections of the proposed rule, which further delineate our concerns and recommendations.
Again, HAP appreciates the opportunity to submit these comments and recommendations. If you have any questions regarding our comments, please contact me or Robert E. Greenwood, HAP’s vice president, health care finance and insurance, at (717) 561-5358; or Lynn Leighton, HAP’s vice president, professional and clinical services, at
(717) 561-5308.
Sincerely,
CAROLYN F. SCANLAN
President and Chief Executive Officer
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