Next year, the CMS plans to add more conditions to the no-pay list. The most likely additions are ventilator-associated pneumonia, staphylococcus aureus septicemia, deep-vein thrombosis (DVT), and pulmonary embolism.
The CMS rule obviously directly affects hospital income, which will affect hospital processes and staff.
“As hospitalists, this affects us,” says Winthrop F. Whitcomb, MD, director of clinical performance improvement at Mercy Medical Center in Springfield, Mass., director of hospital medicine at Catholic Health East, and co-founder of SHM. “It’s another thing showcasing the value of hospitalists because we tend to document well. When a patient comes in with DVT or a pressure ulcer, we tend to document that, and that will help our hospitals.”
Other physicians may balk at hospital requests to amend or add to their notes to ensure payment, but, says Dr. Whitcomb: “Hospitalists understand the requirement for documentation. If you’re not a hospitalist, you may not be happy to be asked to change your documentation so that the hospital can get paid more, but we understand how important this is.”
Hospitals likely will continue to closely oversee physician documentation on Medicare patients.
“At our hospital, we [already] work with coders,” Dr. Whitcomb says. “I’ve heard of this more and more. They round with us now on every Medicare patient and review the charts. They actually write a formal note that prompts us to document accurately—they may ask us to amend that something was present on admission.” Dr. Whitcomb’s hospital has a paper-based system for this information; an electronic system will include this type of prompt. “Electronic prompts can be customized, but they can also be ignored; prompt fatigue is a big issue,” Dr. Whitcomb warns.
Another potential effect on hospitalists will be involvement in hospital efforts to prevent the eight conditions.
“The CMS change is definitely going to up the ante for quality improvement and patient safety work, no matter who undertakes it,” Dr. Whitcomb says. “It should expand opportunities for hospitalists to work in [quality improvement]. Hospitalists may end up leading teams to specifically address certain never events. The good news is, it gets right at the bottom line of the hospital, so nonclinicians like administrators in the financial office will immediately understand the importance of work like this.”
Leaving a sponge inside a patient is clearly a preventable medical error—but what about pressure ulcers? Or DVT?
In his “Wachter’s World” blog post of Feb. 11 (www.wachtersworld.org), Robert Wachter, MD, professor and associate chairman of the Department of Medicine at the University of California, San Francisco, addressed the CMS rule.
“For some of the events on the Medicare list, particularly the infections (such as catheter-related bloodstream infections), there is good evidence that the vast majority of events can be prevented,” Dr. Wachter wrote. “For others, such as pressure ulcers and falls, although some commonsensical practices have been widely promoted (particularly through IHI’s 5 Million Lives campaign), the evidence linking adherence to ‘prevention practices’ and reductions in adverse events is tenuous. These adverse events should stay off the list until the evidence is stronger.”
In spite of his misgivings, Dr. Wachter is a strong proponent of the trend toward nonpayment for preventable errors. “We’ve already seen hospitals putting far more resources into trying to prevent line infections, falls, and [pressure ulcers] than they were before,” he says. “And remember that the dollars at stake are relatively small. The extra payments for “Complicating Conditions” (CC) are not enormous, and many patients who have one CC have more than one; in which case, the hospital will still receive the extra payment even if the adverse event-related payment is denied. So, in essence the policy is creating an unusual amount of patient safety momentum for a relatively small displacement of dollars – a pretty clever trick.”