NAPH Submits Comments on OPPS Proposed Rule - September 7, 2011

On Aug. 30, NAPH submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed calendar year (CY) 2012 Outpatient Prospective Payment System (OPPS) rule. NAPH strongly urged CMS to reconsider its previous decision to include hospital acquired condition measures, Agency for Healthcare Research and Quality measures, and the Medicare spending per-beneficiary measure in the Hospital Value Based Purchasing (VBP) Program for fiscal year (FY) 2014. NAPH has concerns that CMS may compromise the reliability of outcome and efficiency measures by selecting a VBP performance period of less than 1 year. If CMS continues to move forward with these measures, NAPH has proposed that CMS lower the weighting that these measures would be given when calculating hospitals’ overall VBP scores.

In its letter, NAPH also urged CMS to delay the adoption of additional chart-abstracted measures in the Outpatient Quality Reporting (OQR) Program until the electronic reporting of quality measures is both feasible and reliable. NAPH also recommended that CMS include more diabetes process rather than management measures in the OQR Program. In addition, NAPH urged CMS to not finalize the diabetes eye exam measure and the cardiac rehabilitation referral measure and to delay adoption of the surgical site infection measure and the influenza vaccination coverage measure. For more details, please contact Kevin Van Dyke at kvandyke@naph.org.