Medicare's value-based purchasing program that starts in fiscal year 2013 relies on too many quality measures, some of which are not appropriate for all hospitals, asserts provider alliance VHA Inc. in a comment letter to the Centers for Medicare and Medicaid Services.

Beginning Oct. 1, 2012, Medicare will link payments to hospitals to quality outcomes and patient perceptions of care under the VBP program. However, a proposed rule published in January enables CMS to add additional measures in future years by making those measures applicable after being displayed for one year on the government's Hospital Compare Web site, rather than through the formal rulemaking/comment process. VHA opposes use of a "subregulatory process to incorporate additional measures into the VBP program," according to the comment letter.

VHA in the letter also expresses concern that patient perceptions culled from the Hospital Consumer Assessment of Healthcare Providers and Systems survey also will factor into payment. Regional and culture factors appear to make it difficult for some hospitals to score well on the survey, the organization notes.

VHA also notes that hospitals could be accountable for as many as 50 VBP measures by 2014. "VHA believes that CMS should judiciously select a reasonable number of measures that reflect the priorities for the health care system in a meaningful manner," the letter states.

Full text of VHA's comment letter is available here.

--Joseph Goedert


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