The following letter was submitted on behalf of AHQA’s members as part of the comment period for the MACRA Proposed Rule. To download a PDF version of this letter, click here.

Andrew M. Slavitt, Acting Administrator
Centers for Medicare & Medicaid Services (CMS)
U.S. Department of Health and Human Services
Attention: CMS-5517-P
P.O. Box 8013
Baltimore, MD 21244-8013

Dear Acting Administrator Slavitt:

Thank you for the opportunity to comment on the proposed rules for Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician Focused Payment Models.

Our organization, the American Health Quality Association (AHQA), represents the Quality Innovation Network-Quality Improvement Organizations (QIN-QIOs) and their quality improvement partners throughout the United States, Puerto Rico, the Virgin Islands, and the outer Pacific islands. Our association’s goal is to make health care better, safer, and available at a lower cost.

As Medicare-funded organizations charged with working with providers, beneficiaries, families, and stakeholders to improve quality for our nation’s seniors, QIN-QIOs are keenly interested in the provisions of the proposed rule. We strongly support the core principles outlined in the Notice of Proposed Rule Making (NPRM) of simplification and reduction of administrative burden for clinicians and providers. We endorse the effort by CMS to reduce the payment compliance burden for providers without sacrificing the goal of improving outcomes for patients and families.

Below are our comments regarding each of the four performance categories within the NPRM.

QUALITY DOMAIN

We urge CMS to design and make widely available a self-assessment tool that would permit providers to assess their performance against the quality measures benchmarks CMS intends to publish on a routine basis. It is imperative that eligible providers be offered the opportunity to gauge their performance on the quality measures well ahead of the deadline for data submission so that they may have the chance to make any necessary adjustments to improve their performance. In a similar fashion, CMS should encourage Electronic Health Records (her) vendors to provide the functionality needed for providers to easily access the data to evaluate their performance against the MIPS quality domain measures on an ongoing basis.

In addition, we encourage CMS to leverage its network of QIN-QIOs to assist providers in using the self-assessment tool to determine performance against the MIPS standards, and offer providers technical assistance to address performance shortcomings. QIN-QIOs have worked for more than a decade supporting clinicians in reporting quality data (PQRS, etc.) to CMS and have worked with providers to redesign care practices and workflow to improve performance on quality metrics.

We urge CMS to review the approach it intends to take in scoring “topped out” quality measures. The determination of whether a provider should or should not receive maximum credit for achieving 100% compliance on a performance measure should not be predicated on the number of colleagues reaching a similar level of achievement. Such an approach sends the wrong message to providers, inasmuch as it implies that performance measure excellence is the product of the number of providers attaining such a high level of performance, rather than the performance of any one provider.

We suggest that CMS consider adjusting the scoring methodology under this domain to recognize year-over-year performance improvement on each of the quality measures. CMS has substantial experience designing quality measurement programs that recognize absolute performance as well as relative improvement. We believe a similar, two-prong scoring approach to the MIPS quality domain scoring, starting in Year 2 of the program, makes the most sense.

We strongly encourage CMS to consider keeping the set of MIPS quality domain measures the same for a two- to three-year period and that the agency require and/or offer incentives to providers to report on the same measures for more than one year. Since quality improvement interventions usually take more than a single year to take hold and result in actual performance change, the opportunity to report on the same set of quality measures for more than one year (year over year) would allow providers the opportunity to focus on making meaningful improvements to the quality of care they deliver to their patients. 

RESOURCE USE

We encourage CMS to reconsider the use of a minimum sample size of 20 for calculating the resource use measures. While we understand that reducing the sample size from 125 (under the Value-Based Payment Modifier (VBPM) program) to 20 is intended to increase the number of qualifying resource use measure calculations for the program, the literature on quality and resource use measures has consistently shown the need to use sample sizes of no smaller than 100 in most cases for measures calculation to achieve statistical stability. Given the financial consequences surrounding the MIPS program, we suggest that CMS reconsider the minimum sample size to qualify a provider for an episode of care measure under the resource use domain.

As noted above in the Quality Domain performance category, we suggest that CMS consider adjusting the scoring methodology under this domain to recognize year-over-year performance improvement on each of the quality measures. We reiterate that CMS has substantial experience designing quality measurement programs that recognize absolute performance as well as relative improvement. We believe a similar, two-prong scoring approach to the MIPS resource use scoring, starting in Year 2 of the program, makes the most sense.

We are concerned about physicians and providers who do not have access to a health information exchange. In these cases, we recommend a hardship exemption option for this objective.

Since the EHR Incentive program still exists for Medicaid providers, it is unclear if the EHR vendors will be required to provide two sets of reports (one for each program). We recommend aligning Medicaid EHR Incentives and Medicare MIPS quickly, as well as requiring EHR vendors to submit quality measures and attestations for all three MIPS categories—Quality, Advancing Care Information (ACI), and Clinical Practice Improvement Activities (CPIA).

We also suggest incorporating some increased value, via bonus points, for EHR reporting. Certainly, one of the goals with the EHR incentive program was to build, design, and maintain systems which capture important data points for quality measurement in a consistent, structured manner. Increasing the value of reporting via the EHR reporting method encourages clinicians to use their EHR systems in a manner to promote better visibility and granularity with quality data, as well as urges EHR vendors to make this functionality more available and streamlined to gather, track, and trend quality data. Expending multiple hours to extract or abstract data is an inefficient use of time and materials and diverts clinicians away from improvement activities.

The MIPS rule specifies that MIPS-eligible clinicians submitting data for the ACI category are required to collect data from all locations where they provide service and aggregate the data for these measures. Requiring information from all practices locations across TINs is an unnecessary burden which can be eliminated as it serves no useful purpose. We recommend that the same process currently utilized for PQRS be adopted for MIPS, allowing for a TIN/NPI combination for reporting for all three MIPS categories. In this way, each clinic will be responsible for reporting for all NPIs that perform services at their clinics.

Multiple mechanisms are available for providers to submit their quality measures, ACI, and CPIA. We recommend streamlining the submission process for all categories, whether a measure or attestation, using the same standardized format. For example, EHR vendors, registries, and QCDRs would be required to use the same QRDA I or III format to streamline submission of all three categories of MIPS.

We recommend reducing the number of Electronic Clinical Quality Measures (eCQM) revisions per year. Current experience shows the EHR vendors often cannot or do not update the software and reports in enough time for providers to accurately monitor their measures to ensure success. The reality of time delays, based on updates, handoffs and system upgrades needs to be recognized.

Additionally, we ask that CMS consider eliminating the various requirements pertaining to the different reporting mechanisms. We urge that CMS make the eCQM specifications (found on eqi.healthit.gov) the baseline specifications, regardless of the reporting mechanism. We recommend that CMS not change volume requirements based on which mechanism is utilized for reporting purposes. The only difference should pertain to whether practices include all encounters or only Medicare FFS encounters.

CPIA Domain

The relatively low weighting of CPIA (15% of the total score in Year 1) would seem to undercut the goal of actively encouraging providers to commit to the infrastructure necessary to achieve long-term success. The broad emphasis on care coordination, beneficiary engagement, and patient safety is appropriate, but we believe CMS should include a fourth category that allows practices to focus on office efficiency/operations.

The program currently identifies an annual update to the list of approved activities. While this is a realistic timeframe for revisions, it is important to recognize that practices are likely to develop multi-year improvement strategies and the sudden removal of an approved activity could undermine program stability. For this reason, it is important that topics identified for termination should be allowed to continue for one year beyond initial notification to allow for sufficient notice to participating practices.

While the flexibility of an “a la carte” approach to obtaining CPIA points is sensible, it is important that CPIA efforts be tied to the areas where providers are struggling. Experience has shown that physicians are more likely to participate in programs in areas where they feel confident in their skills, as opposed to areas where they may be struggling or have limited experience. We believe a long-term goal of the CPIA program should be to target Clinical Practice Improvement Activities to identified practice deficiencies.

Given the broad portfolio of individual projects within the QIN-QIOs, we believe that individual credit should be provided for each QIO project that a provider participates in and not simply a uniform point(s) award for any participation.

While we applaud the emphasis on Patient-Centered Medical Home (PCMH) models within the CPIA, it is our understanding that the majority of certification programs do not have a requirement for ongoing, active clinical improvement efforts. AHQA strongly recommends a flexible approach to quality assessment that emphasizes outcomes of care and that favors continuous quality improvement methodologies rather than rigid, process-oriented certification models. Relying on certification as a means of quality assessment runs the risk of practices checking off items but leaving the way they operate intact and not actually realigning efforts to produce higher quality and more cost effective care.

While recognition as a PCMH provides full credit for CPIA to practices, this certification is not an option for many of the specialty physicians that are likewise affected by the Quality Payment Program (QPP). As such, we recommend that the rulemaking process be used to also allow full credit for specialty practices receiving PCMH Specialty Practice Recognition.

We note that “non-patient facing” providers can perform a single activity, instead of having to meet full requirements. We are concerned that this exception implies a lesser need for quality improvement within these practices. We maintain that Clinical Performance Improvement Activities are equally valuable for all medical specialties and that all providers should be held to the same standard.

The rationale for CPIA half credit for participation in Advanced Alternative Payment Models (APMs) is unclear, in light of the full credit for PCMH participation. Success in APMs is dependent upon CPIA and therefore we believe that full credit should be extended to practices participating in those models as well.

Although potentially blurring the lines of the point categories, we believe that it is valuable to recognize those quality improvement efforts that have not yet been formally adopted by the program. To recognize these innovative efforts, we propose that an improvement threshold be set for quality measures and that attainment of this level of improvement be considered evidence of CPIA and rewarded with CPIA points.

We recognize the value of a broad approach to improvement, but believe that many efforts require a multi-year approach. For this reason, we propose that individual topics may be pursued by an individual provider for up to three years, but that following this period, providers be required to select a different area of focus.

Given the aggregated data model for physicians with multi-site practices, it isn’t clear how this issue is to be handled regarding CPIA. Due to the significant effort required at each site and the general lack of “economy of scale” for quality improvement efforts across multiple practice locations, we believe that a provider should be allowed to receive points for each site in which they are participating.

An early introduction of the CPIA program, prior to the 2019 rollout of the remainder of the project, could serve to “ramp-up” efforts that allow practices to build the infrastructure needed for their eventual success and allow a low-risk, phasing-in approach to the scoring aspects of the QPP.

As part of efforts aimed at administrative simplification, we believe that a valuable service could be presented by QIN-QIOs through their direct reporting of participating providers’ CPIA activities.

One way to align quality improvement expertise provided to practices across the nation would be for MIPS support contractors to rely on the same elements of practice transformation that are being rolled out in the Transforming Clinical Practice Initiative (TCPI). Under this scenario, MIPS support would focus on the five phases and milestones being utilized for TCPI in primary and specialty care. These consist of: Phase 1 (aim setting/capacity building), Phase 2 (reporting and using data to improve quality), Phase 3 (achieving lower costs, better care, and better health), Phase 4 (getting to benchmark status), and Phase 5 (demonstrating sustained capability to generate better care and better health at lower cost).

Advancing Care Information (ACI)

We applaud efforts to advance the exchange of health care information. We have concerns that the interoperability requirements permitting exchange of clinical messages with providers using another EHR system will prove to be quite costly. We strongly recommend that interoperability costs be the responsibility of the EHR vendors. There are many instances in which one provider sends a Creditable Coverage Disclosure (CCD) to another provider with another system, but the receiving system cannot open it. The Comprehensive Primary Care plus (CPC+) model requires that the EHR vendors meet the necessary requirements at no additional cost. This model should be applied for MIPS.

If the Office of the National Coordinator for Health Information Technology (ONC) authorized bodies find that a provider is unable to open a CCD from another provider with a different EHR, the penalty should be assigned to the EHR Vendor as opposed to the provider. Indeed, it is our understanding that some EHR vendors are using their own version of CCDs, which render them unusable by other EHR vendors.

Additionally, the rule needs to provide clarification on when eligible hospitals must also be compliant with Stage 3 ACI-like measures, insofar as many of them attested to both Medicare and Medicaid. Physicians and hospitals need to be able to communicate effectively for physicians to be successful regarding this measure.

We anticipate security to be the biggest risk in the MIPS ACI requirements. Physicians still do not have an accurate understanding of what is required in a risk analysis, and it appears that few rural, small, or solo physician practices have conducted full analyses. We recommend continuing education on this topic.

Supplemental Information

Suggested Educational Resource

There has been discussion amongst the QIN-QIOs about who is considered/qualifies as an eligible clinician and for which categories. We have found that visual displays outlining which providers are subject to which categories of MIPS (such as in the table below) offer clear, concise guidance, are well received by providers, and help to eliminate confusion. We recommend that CMS utilize this table or a similar tool to aid in communication and education efforts around the payment models.

Rural Health Centers (RHCs) and Federal Qualified Health Centers (FQHCs)

Services billed under RHCs/FQHCs are currently exempt from Physician Quality Reporting System (PQRS) and Value Modifier. This exemption has provided necessary shelter for these programs and prevented them from expending valuable resources attempting to meet criteria for multiple quality programs during the same timeframe. We support the proposal to exclude RHCs/FQHCs from the MIPS all-inclusive payment rate.

Rural Health Centers (RHCs) and Critical Access Hospitals (CAHs)

Presently, some providers offering services at RHCs also provide Medicare Part B Physician Free Schedule (PFS) services which are subjected to PQRS. An example would be providing services in a Critical Access Hospital (CAH) such as emergency medicine and outpatient procedures. The Certified EHR Technology (CEHRT) in the CAH is not configured to give accessibility to electronic Clinical Quality Measures for eligible clinicians as the hospital CEHRT is designed to provide electronic Clinical Quality Measures mapped to the Hospital Inpatient Quality Reporting (HIQR) measures rather than the PQRS measures. The eligible clinicians typically have a greater patient volume in the clinic as well as an increased ability to effect positive change in quality measures in the clinic. In the above scenario, quality measures for eligible clinicians are required from the CAH, where they see fewer patients, have less ability to impact change, and must extract measurement data manually. Substantial resources are being spent gathering data rather than implementing improvement programs.

Our recommendation is to allow providers in a CAH to submit data to MIPS for all appropriate categories from the RHC setting in lieu of submitting data from only the setting in which the Medicare Part B PFS claims are submitted.

Thank you for the greatly appreciated opportunity to comment on the proposed rule for the Quality Payment Program and the MIPs or APM paths. We believe our observations, comments, and recommendations are aligned with and in support of CMS and Congresses’ intent with MACRA, as well as the long history and demonstrated successes of the QIN-QIOS in partnering with CMS to achieve substantive improvement in health care quality.

Regards,

Colleen Delaney Eubanks, CAE

Executive Director

Report highlights newly-implemented structural changes, early progress, and anticipated changes for year ahead

The American Health Quality Association (AHQA) applauds the Centers for Medicare & Medicaid Services (CMS) for releasing the 2014 QIO Program Progress Report, which highlights how Quality Innovation Network-Quality Improvement Organizations (QIN-QIOs) nationwide are bringing together local providers, partners, and other stakeholders to achieve rapid improvements in health quality.

“AHQA is pleased to help CMS spread the word about the accomplishments of this program and how QIOs are engaged in their communities across the country to achieve the goals of better health care, a healthier population, and lower cost,” said Todd Ketch, Executive Director, AHQA. “The Progress Report is a clear snapshot of the QIO Program and demonstrates the benefits of QIO initiatives for patients and their care providers.”

The interactive online report features the following:

• Information about the QIO Program’s new organizational structure, its goals and national partnerships
• Real-life examples of how health care providers have addressed quality improvement challenges
• Takeaways from CMS’ 2014 QualityNet Conference, which was attended by providers, beneficiary advocacy groups, federal agencies, health care quality improvement organizations, and others

“We know this report shows just some of what’s possible with the QIO program,” said Dennis Wagner, Acting Director of the Centers for Medicare & Medicaid Services (CMS), Center for Clinical Standards and Quality, Quality Improvement Group. “We look forward to continuing this momentum toward even greater community collaboration with QIOs to achieve truly transformational results.”  

The report highlights some of the recent achievements QIOs made from 2011 to 2014 in their recently-completed 11th Statement of Work contract cycle with the Centers for Medicare and Medicaid Services (CMS):

• 27,000 readmissions and 95,000 hospitalizations avoided, and nearly $1 billion cost savings from improving care transitions
• 44,640 potential adverse events prevented
• 53 percent reduction in central line associated blood stream infections
• 85,149 fewer days with urinary catheters for Medicare beneficiaries
• 3,374 pressure ulcers prevented or healed in 787 nursing homes
• 6,250 Medicare beneficiaries in 981 nursing homes are now restraint free
• 20 percent rate of absolute improvement in blood sugar control among participating diabetics

In addition, the 2014 QIO Program Progress Report profiles programs that have achieved better health, better care, and lower costs. The report concludes with the ambitious five-year QIO program goals that ensure the continued work of the QIOs to aggressively pursue opportunities for improvement.

Learn More:

CMS on QIO Program impact on U.S. health care in recent years

Find out more about QIOs in Action in their communities

Media Contact:
Todd Ketch | (202) 331-5790 | tketch@ahqa.org

About The American Health Quality Association (AHQA):  AHQA is an educational, not-for-profit national membership association dedicated to promoting and facilitating fundamental change that improves the quality of health care in America. AHQA represents Quality Improvement Organizations (QIOs) and other professionals working to improve health care quality and patient safety. For more information, visit www.ahqa.org.

All hospitals participating in the survey that worked with QIOs in 2013 (over half of all acute care hospitals in the country) reported deriving direct benefit from their QIO interactions.

The American Health Quality Association (AHQA)—representing the newly-restructured network of Quality Innovation Network-Quality Improvement Organizations (QIN-QIOs), across the U.S.—is pleased to comment on the report of the survey of acute care hospitals recently published by the Office of the Inspector General of the U.S. Department of Health and Human Services (HHS-OIG). “AHQA is gratified that all hospitals that participated in the HHS-OIG survey report that they received benefit from working with QIOs, with a majority of respondents citing the value our member organizations provide in connecting hospitals on similar quality-focused projects, defining clinical measures to track, and developing and explaining comparative data reports,” said Todd Ketch, AHQA’s Executive Director. “We view the work QIOs do as synergistic with other federal quality improvement efforts, such as the Hospital Engagement Networks and the Community-based Care Transitions Program, which are key elements of the public-private Partnership for Patients initiative. We share the view expressed by the Centers for Medicare & Medicaid Services (CMS) that large-scale health care quality improvement requires careful and sustained coordination of efforts across different programs.”       

Learn More:

CMS on QIO Program impact on U.S. health care in recent years

AHQA’s December 2014 comments on the continuation of the Hospital Engagement Network Program

Media Contact:
Todd Ketch | (202) 331-5790 | tketch@ahqa.org

QIOs have a significant role in the National Partnership to Improve Dementia Care, which exceeded a previous goal to reduce the use of antipsychotic drugs among nursing home residents

Washington, D.C. — Dr. Adrienne Mims, vice president and chief medical officer of Atlanta-based Alliant GMCF, the Quality Innovation Network (QIN) Quality Improvement Organization (QIO) for Georgia and North Carolina, and president of the American Health Quality Association (AHQA), released the following statement regarding the U.S. Centers for Medicare & Medicaid Services’ (CMS) announcement of new national goals to reduce the use of antipsychotic medications among nursing home residents.

“AHQA applauds CMS for continuing its commitment to provide better health care and enhance the quality of life for nursing home residents with dementia by establishing new national goals for the National Partnership to Improve Dementia Care. The work of QIOs was integral to the prior success of the partnership, which reduced the national prevalence of antipsychotic drugs in long-stay nursing home residents by 15.1 percent from 2011 to 2013, and QIOs will work closely with providers to achieve the new goals of a 25 percent reduction by the end of 2015 and a 30 percent reduction by the end of 2016.

“QIOs work hand-in-hand with local providers, consumers, and stakeholders across the continuum of care—including in nursing homes—to improve systems of health care delivery and ensure better, safer health care. The American Health Quality Association represents the national network of QIOs working to advance the quality of care for America’s nearly 50 million Medicare beneficiaries.

“The effort to reduce the inappropriate use of antipsychotic drugs is a significant portion of QIO efforts to support quality improvements in thousands of nursing homes across the nation. In addition to helping to accelerate the goals of the National Partnership to Improve Dementia Care, QIO efforts complement the Advancing Excellence in America’s Nursing Home Campaign. Among other improvements, QIOs helped low-performing nursing homes achieve a 34 percent reduction in high-risk pressure ulcers among residents from 2011-2014.

“QIOs look forward to furthering their work with CMS and other partners in nursing homes across the country in the coming months to spread knowledge and meet the CMS partnership challenge. These efforts reflect a deep commitment to protecting nursing home residents and promoting person-centered care.”

Media Contact:

Sofia Kosmetatos | (202) 603-8516 | skosmetatos@ahqa.org

Centers for Medicare & Medicaid Services (CMS) announces new, five-year contracts for regional Quality Improvement Organizations; nearly $1B in savings identified in previous cycle

Washington, D.C. — The American Health Quality Association (AHQA) offered its congratulations today to recipients of Quality Improvement Organization (QIO) contracts following an announcement by the Centers for Medicare & Medicaid Services (CMS). The contract awards are for organizations that will work directly with providers and communities on quality initiatives to improve health care provided to—and the overall health of—Medicare patients. Earlier this year, a CMS analysis found that QIOs facilitated improvements in care transitions that led to nearly $1 billion in savings during the previous three-year contract cycle.

The new contracts, which begin August 1, were awarded to 14 organizations nationwide. Contract recipients include:

• Atlantic Quality Improvement Network (District of Columbia, New York, South Carolina)
• Georgia Medical Care Foundation (Georgia, North Carolina)
• Great Plains Quality Innovation Network (Kansas, Nebraska, North Dakota, South Dakota)
• Health Services Advisory Group (Arizona, California, Florida, Ohio)
• Healthcentric Advisors (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont)
• HealthInsight (Nevada, New Mexico, Oregon, Utah)
• Lake Superior QIN/Stratis Health (Michigan, Minnesota, Wisconsin)
• Mountain Pacific Quality Health Foundation (Alaska, Hawaii, Montana, Wyoming)
• Qsource (Alabama, Kentucky, Mississippi, Tennessee)
• Qualis (Idaho, Washington)
• Telligen (Colorado, Illinois, Iowa)
• TMF (Arkansas, Missouri, Oklahoma, Texas)
• VHQC (Maryland, Virginia)
• WVMI Quality Insights (Delaware, Louisiana, New Jersey, Pennsylvania, West Virginia)

* The Indiana, Puerto Rico, and Virgin Islands awards have not yet been determined.

“The contracting structure of the QIO Program has changed, but the focus of the QIOs remains the same—to drive quality improvement at the community level,” AHQA Executive Director Todd D. Ketch said. “For 30 years, the work of QIOs has been instrumental in a number of improvements that impact Medicare beneficiaries, most recently including reducing avoidable hospital admissions and readmissions, reducing pressure ulcers, and preventing potential adverse drug events. QIOs represent the ‘boots on the ground’ infrastructure for implementing HHS’ National Quality Strategy and other broad national health care improvement goals.”

Such goals include reducing health care-associated infections (HAIs), improving preventive care, reducing deaths from heart attack and stroke, and broadening the use of electronic health records. AHQA’s network of QIO professionals, from physicians to frontline nurses to communicators, helps provide quality improvement expertise every day in communities nationwide.

“I look forward to the QIOs’ continued efforts to help provide Medicare patients with the best, safest care possible no matter when or where they receive care,” said AHQA President Adrienne Mims, MD, MPH, who also serves as vice president and chief medical officer for Georgia-based Alliant GMCF. “While the goal remains improving care for Medicare beneficiaries, recent QIO successes point to the fact that this work positively impacts the care of every American who accesses our nation’s health care system.”

The contract recipients will be Quality Innovation Network QIOs, under a restructured QIO Program that separates the program’s case review work and quality improvement activities and extends contracts to five years from three. CMS has also moved to a regional contracting structure for the program.

In the years ahead, CMS will work with QIOs to focus on improving the way in which providers coordinate patient care across settings; reduce HAIs; improve care for high-incidence, chronic conditions like diabetes and heart disease; and more.

The work will build upon successes from the most recent three-year contract cycle (2011-2014), which included nearly $1 billion in cost savings nationally from the prevention of 95,000 hospitalizations and 27,000 hospital readmissions. QIOs also helped prevent 45,000 potential adverse drug events and prevent or heal nearly 3,400 pressure ulcers. Additionally, QIOs’ work with hospitals across the nation drove a 53 percent reduction in central line associated blood stream infections.

Media Contacts:
Sofia Kosmetatos | (202) 603-8516 | skosmetatos@ahqa.org
Haydn Bush | (202) 745-5073 | hbush@gymr.com

Nation’s Quality Improvement Organizations Prove Instrumental in Reducing Hospital Readmissions, Health Care Associated Infections

Washington, D.C.—New data from the Centers for Medicare & Medicaid Services (CMS) show that the nation’s Quality Improvement Organizations (QIOs), working in close partnership with providers, federal, state and private partners and others in local communities, have prevented more than 95,000 hospitalizations and 27,000 hospital readmissions among Medicare beneficiaries. From October 2010 to March 2013, CMS data indicate that hospital readmissions among Medicare beneficiaries declined by 13.22 percent in QIO communities, compared to a national drop of 12.55 percent. Similarly, hospital admissions also declined further in QIO communities—by 8.39 percent vs. 8.12 percent nationally—pointing to the efforts of QIOs as an important lever in improving health care quality nationwide.

By improving care transitions—when patients move from one care setting to another, such as from a hospital to their home—these reduced hospitalizations, including in QIO communities, resulted in a cost savings of nearly $1 billion. While progress has been made nationwide to improve care transitions and reduce the number of patients who return to the hospital within 30 days, CMS’ findings indicate that readmissions have been reduced further in communities where QIOs play an active role.

“QIOs work in close partnership with physicians, nurses and other members of the interdisciplinary team across settings—forming a network that helps patients remain healthy long after they leave the hospital,” said Adrienne Mims, MD, Vice President, Chief Medical Officer of Atlanta-based Alliant GMCF, the QIO for Georgia, and president of the American Health Quality Association (AHQA). “Because QIOs are part of the local community—neighbors, in fact—we’re able to constantly innovate and adapt, ensuring our efforts meet the unique needs of local seniors and their families. Successfully reducing readmissions takes the entire community.”

Keeping seniors out of the hospital is just one of many of the QIOs’ measurable improvements in the quality of care provided to the nation’s nearly 50 million Medicare beneficiaries. In intensive care units and other hospital units in more than 800 facilities nationwide, QIOs provide assistance to help reduce healthcare associated infections (HAIs). From February 2011 to August 2013, QIOs’ efforts resulted in a 53.0 percent reduction in central line associated blood stream infections.

A major source of HAIs is catheter associated urinary tract infections, or CAUTIs. One intervention for successfully reducing CAUTIs is to cut down on the number of days in which a patient needs a catheter. In total, QIO-assisted hospitals were able to reduce the total number of Medicare patient days in which a catheter was used by more than 85,000 days nationwide.

“As rates of chronic disease increase and the baby boomer generation ages, it’s essential that we improve the quality of health care provided to America’s seniors,” said Todd Ketch, executive director of AHQA. “We owe them an improved care experience, so that they may maintain their quality of life for as long as possible. There is an imperative to achieve substantially better quality, improved safety and increased efficiency in health care. Ensuring seniors receive the right care at the right time, and empowering them to make informed decisions about their own care also brings down health care costs, which ultimately benefits everyone.”

Funded by the federal government, Medicare QIOs have been working to improve patient care for 30 years by collaborating with providers, consumer advocates and others to improve health care delivery, safety and efficiency in every state and U.S. territory. The national network of QIOs is the country’s longest-standing, nationwide program to improve health care quality. In August 2014, CMS will implement a new contract for QIOs—aligned with the U.S. Department of Health & Human Services’ National Quality Strategy and specifically focused on improving the health status of communities; providing beneficiary-centered, reliable, accessible and safe care; and providing better care at a lower cost.

“Our nation needs to support quality improvement and technical assistance to providers at the local level to achieve higher quality of care, prevent patient harm, and improve health outcomes,” said Patrick Conway, MD, MSc, Chief Medical Officer for CMS and Deputy Administrator for Innovation and Quality. “Quality Improvement Organizations have driven major improvement in quality of care across the nation and in the years ahead, our work with QIOs will focus on coordinating patient care across settings, reducing health care associated infections, improving care for common conditions like diabetes and heart disease, and more.”

AHQA represents the national network of QIOs working to advance the quality of health care for America’s Medicare beneficiaries. In every state, QIOs work hand-in-hand with local providers, consumers, and stakeholders across the continuum of care—including in hospitals—to help ensure that when our nation’s Medicare beneficiaries receive medical care, regardless of the setting, it’s the best and safest care possible.

Media Contact:

Todd Ketch | (202) 331-5790 | tketch@ahqa.org