The move to eliminate payments to providers who make mistakes isn't that easy, noted the American Hospital Association in a letter to the Centers for Medicare & Medicaid Services.
In commenting on a national analysis of errors involving patients undergoing the wrong surgery or surgery on the wrong patient or body part, the AHA noted that several factors have to be taken into account, rather than having Medicare indiscriminately withholding payment.
Beginning October 1, Medicare is planning to withhold payments to hospitals for eight "never events," which are hospital-acquired conditions or occurrences that result from mistakes in treatment.
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Other payers, and even state hospital groups, say they plan to follow the same rationale as CMS, but the AHA letter suggests that several mitigating factors must be considered, and an overall approach needs to be defined.
The association, which represents the nation's more than 5,000 hospitals, recently adopted a set of principles that describe when hospitals should not expect payment for care related to preventable serious adverse events.
In its letter, the AHA urged CMS officials to consider three key questions as it begins deliberations on a national coverage determination for the three surgical conditions. Those questions focus on how the events are defined; how will accountability be assigned, and what costs or services should not be covered,
"CMS must thoughtfully and carefully define the events it includes under the national coverage determination," said the AHA letter, which was signed by Rick Pollack, executive vice president.
In states that have initiated reporting of serious adverse events, the AHA has seen hospitals report more events as they gain experience with reporting programs. These include smaller errors, or mistakes that bear more significance for quality improvement programs.
"However, what is valuable for learning and quality improvement purposes may not always be appropriate for payment policy," the AHA noted. "CMS coverage decisions should not stifle the reporting of these events."
CMS also needs a policy for what to do when a provider starts a procedure on a wrong site, discovers the error, stops the procedure and begins again on the correct site.
"Finally, because of the many nuances surrounding the issue, we recommend that CMS include in the national coverage determinations an appeal process for hospitals to petition any decisions that they believe were made inappropriately," the AHA letter stated.