The issues and challenges related to how hospitals collect and submit quality data to CMS and how CMS ensures the reliability of the quality data submitted was the focus of testimony given by Linda T. Kohn, Government Accountability Office (GAO) Acting Director, Health Care before the Senate Finance Committee on March 6, 2008.
CMS' Annual Payment Update (APU) program requires participating hospitals to submit quality data for calculation of hospital performance on quality-of-care measures. In the APU program, each quality measure consists of a set of standardized data elements. Hospitals determine a value for each data element for all patients, both Medicare and non-Medicare, who have a medical condition covered by the APU program. The values of the data elements consist of the numerical data and other administrative and clinical information that is obtained from the patients' medical records.
Collecting and submitting data. The GAO reported in April 2007 that eight case study hospitals used the following six steps to collect and submit quality data to determine the appropriate value for each data element: (1) identify patients for whom the quality data should be submitted; (2) locate needed information in the medical records; (3) determine the appropriate value for each data element; (4) transmit the data to CMS; (5) review reports to ensure CMS' acceptance of the data; and (6) supply copies of selected medical records to CMS for data validation.
The GAO's case studies showed that existing information technology (IT) systems help hospitals gather some quality data but are far from enabling hospitals to automate the abstraction process. IT systems offer hospitals two key benefits: (1) improving accessibility to and legibility of the medical record; and (2) facilitating the incorporation of CMS' required data elements into the medical record.
Validating data. CMS has a process for ensuring accuracy but has no ongoing process for ensuring completeness of quality data. CMS' determination as to whether hospitals have met the accuracy standard, however, was statistically uncertain for some hospitals because of the small number of records examined—five per quarter, regardless of
CMS does not have an ongoing process for assessing the completeness of quality data submitted by hospitals. For fiscal year 2008 and subsequent years, CMS is requiring that hospitals attest to the completeness and accuracy of their data quarterly. CMS plans to redesign the data infrastructure and validation process (e.g., by increasing the number of patient medical records sampled from select hospitals) to support a value-based purchasing program.
GAO Testimony, GAO-08-555T, March 5, 2008.
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