CMS published its proposal in April, well in advance of the new fiscal year that begins in October, because CMS is interested in seeking public comments on “the degree to which (each condition) is reasonably preventable through the application of evidence-based guidelines.”
Based on public comment, CMS will choose to select or not select each condition listed as a hospital-acquired condition. CMS is expected to make its decision known by the end of this month. Let it be known that this hospitalist is opposed to the delirium measure. I am not alone. A number of professional societies, including SHM, American College of Chest Physicians, Society of Critical Care Medicine, American Thoracic Society, among others, have expressed reservations to CMS about several of the proposed hospital-acquired conditions.
These societies believe ventilator-associated pneumonia, DVT/PE, and iatrogenic pneumothorax also should not be included as hospital-acquired conditions because they, like delirium, are not entirely preventable. Further, they believe the incidence of these four conditions can be reduced by adherence to evidence based guidelines but there is insufficient evidence to guide prevention of these conditions.
In addition, SHM raised concern that listing Legionnaires’ disease as a hospital-acquired condition may lead to unintended consequences, such as routine testing for Legionnaires’ in all patients presenting with community acquired pneumonia.
We won’t know until the end of this month whether CMS will make any or all of these conditions subject to the POA payment provision in fiscal year 2009. But kudos to the professional societies and all who have helped CMS think about these important issues. TH