Life Science Compliance Update

May 22, 2015

Open Payments Data Correction Period: May 21 - June 5

Open Payments CMS

Today, May 21, the Open Payments 15-day data correction period begins for applicable manufactures and group purchasing organizations. The correction period will end June 5. During this time, applicable manufacturers and GPOs should acknowledge and resolve disputes initiated by physicians and teaching hospitals during the review and dispute period conducted between April 6 and May 20, 2015. The 2014 Open Payments data will become public on June 30, 2015. 

The data correction period follows the 45-day dispute process, where physicians and teaching hospitals could inspect manufacturer or GPO submitted data before it is published on the Open Payments website. 

Understand the impact of dispute timing at CMS's resource, Review and Dispute Timing and Data Publication Quick Reference Guide, which provides information on how data is published based on when a dispute is initiated and its dispute resolution status.

"It is important that applicable manufacturers or GPOs work directly with the physician or teaching hospital to resolve any disputes in accordance with the Final Rule, states the Centers for Medicare and Medicaid Services (CMS). The agency notes that it "is not responsible for mediating disputes."

Instructions for the Data Correction Process 

  • Step-by-step instructions regarding the data correction process are available below and on the Resources page of the Open Payments website. 

For Applicable Manufacturers and GPOs

For Physicians and Teaching Hospitals

May 20, 2015

Hospital Compare Update: CMS Adds Star System Rating Patient Experience

Hospital Compare

Hospital Compare is, according to CMS, a “consumer-oriented website that provides information on how well hospitals provide care to their patients.” The website relies on data gleaned from the Hospital Consumer Assessment of Healthcare Providers and Systems, or HCAHPS, survey, to measure patients’ perspectives of the hospital care they receive. Just last month, CMS introduced a star rating system to its Hospital Compare website, in order to “provide a quick summary of each HCAHPS measure in a format that is increasingly familiar to consumers and enable consumers to more quickly and easily assess the patient experience of care information.” CMS clarifies that the new Star Ratings summarize only one aspect of hospital quality: patients’ experience of care. The Hospital Compare website tracks other metrics as well, but the "patient experience" prong is the first to get the star rating treatment. CMS plans to update the ratings each quarter.

The first public reporting of the HCAHPS Star Ratings published last month is based on patients discharged between July 1, 2013 and June 30, 2014. HCAHPS Star Ratings, including the star ratings level thresholds, will be recalculated for each public reporting. 

Hospital Compare

In addition to patient experience, Medicare’s Hospital Compare currently rates hospitals on a wide variety of metrics, including: timely and effective care; readmissions, complications, and deaths; use of medical imaging; payment and value of care; and number of Medicare patients.

Hospital Compare

Hospital Compare lists the results from its “Consumer Assessment,” a national survey that asks patients about their experiences during a recent hospital stay.

The website lists a percentage next to the following eleven questions:

  1. Patients who reported that their nurses "Always" communicated well
  2. Patients who reported that their doctors "Always" communicated well
  3. Patients who reported that they "Always" received help as soon as they wanted
  4. Patients who reported that their pain was "Always" well controlled
  5. Patients who reported that staff "Always" explained about medicines before giving it to them
  6. Patients who reported that their room and bathroom were "Always" clean
  7. Patients who reported that the area around their room was "Always" quiet at night
  8. Patients who reported that YES, they were given information about what to do during their recovery at home
  9. Patients who "Strongly Agree" they understood their care when they left the hospital
  10. Patients who gave their hospital a rating of 9 or 10 on a scale from 0 (lowest) to 10 (highest)
  11. Patients who reported YES, they would definitely recommend the hospital

CMS has now consolidated the percentages to these eleven questions into a "Summary Star Rating" scale from 1 star to 5 stars. CMS created the HCAHPS Star Ratings to enable consumers to more quickly and easily assess the patient experience of care information that is provided on the Hospital Compare website. "Star ratings will also allow consumers to more easily compare hospitals," CMS states.

More Ratings in the Future

"In addition to adding HCAHPS Star Ratings to Hospital Compare in April 2015, CMS is developing a methodology for an overall hospital star rating that includes the full range of quality measures reported on Hospital Compare," state CMS. "We believe that an overall hospital rating will be helpful to consumers by allowing them to more easily compare the quality provided by hospitals." 

CMS already uses star ratings in other Compare websites, as well as in Medicare Plan Finder. Currently, Nursing Home Compare features an overall star rating for each facility and star ratings for other important categories of health care quality. In 2014, CMS introduced star ratings to Physician Compare, which uses them to rate a limited number of measures for group practices. In January 2015, CMS added star ratings to Dialysis Facility Compare and plans to add them to Home Health Compare later this year. Medicare Plan Finder uses star ratings to help beneficiaries select parts C and D plans. These star ratings also determine quality bonus payments for plans.

Controversy

Condensing a hospital's perceived worth down to a 1-5 star rating has caused some in the healthcare industry to question the methodology of CMS's metrics, or at least the value they have for patients seeking quality care. The American Hospital Association, for example, questioned the value of the star ratings. “The reasons that patients seek care from hospitals are varied,” said Akin Demehin, the AHA's senior associate director of policy (see Modern Healthcare). “We are not confident that a star-rating approach—especially one that would encompass all of the measures on Hospital Compare and roll them up into a single overall star rating—is going to give patients the insight on the quality of their hospitals that CMS is hoping for.”

Other articles have questioned whether CMS's rating system is using accurate information for their grades. For their part, CMS urges those using the information to consider multiple factors, including other Hospital Compare metrics, when choosing a hospital. A patient's satisfaction level regarding a nurse's communication skills is important, but those survey results should be paired with patient health outcomes, for example, such as readmission, complication, and mortality rates

Modern Healthcare found that only about 7 percent of hospitals received a 5-star rating, and 19 percent of hospitals received either a 1 or 2. Most received either 3 stars (40 percent) or 4 stars (34 percent). Their article also lists in order of stars, every hospital listed on CMS's website. 

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