Measure 1789: Hospital-wide all-cause readmission measure (the “CMS/Yale measure”), originally endorsed by NQF on April 24, 2012 for purposes of evaluating hospital performance, was challenged by seven hospitals and health systems that expressed concerns regarding the measure’s approval process, its validity, and usefulness. On June 25, 2012, the NQF Board voted to uphold its original decision to endorse the measure, which NQF says “will result in a single summary risk-adjusted readmission rate for conditions or procedures that fall under five specialties: surgery/gynecology, general medicine, cardiorespiratory, cardiovascular, and neurology.” Measure 1789 is designed to estimate “the risk-standardized rate of unplanned, all-cause readmissions to a hospital for any eligible condition within 30 days of hospital discharge for patients aged 18 and older.”
The American Hospital Association (AHA) has expressed procedural concerns about NQF’s use of the expedited review process in its approval of Measure 1789. In addition, AHA strongly urged the incorporation of socioeconomic factors into the measure and raised serious concerns regarding the measure’s usefulness in informing improvement or patient decision-making. As AHA explained in a January 20, 2012 letter:
[T]he existing condition-specific readmission measures create a large category of hospitals that are deemed to be no different in performance from the average, and hospitals find it confusing when they cannot replicate the readmission rate calculated for them. Many factors contribute to this inability to replicate the readmission rate. One of them is the same reason that makes it hard for consumers and purchasers to distinguish among hospitals, and that is the methodology essentially substitutes the national average for the hospital’s own rate except to the extent there is enough data to allow one to say that the hospital’s specific rate is different from the national norm in a statistically reliable way. This means that, for most hospitals, their readmission rate is not wholly their own, but is rather a blend of their own performance and the national average. For smaller hospitals, the calculated rate is predominantly the national average. As hospitals get larger, the rate becomes more their own and less of the national average.
Measure 1789 was formally appealed (through the NQF endorsement process) by seven NQF-member hospitals and health systems, which echoed AHA’s concerns with the measure. The providers noted in their appeal that “less than 20% of the more than 400 NQF members voted on this measure and a disproportionate number of Health Professional and Provider Organization members voted ‘No.’” They argued in favor of a “more robust forum for dialogue and consensus” before the measure is adopted by CMS for public reporting and payment decisions.
In its June 29, 2012 Press Release announcing its decision to uphold its endorsement of Measure 1789, NQF explained that during the endorsement process it “thoroughly vet[s] the proprieties of a measure,” but does not advise on the “best use of measures in payment and public reporting programs.” This is the role of the Measure Applications Partnership (MAP), which has been asked to convene a special session this Summer to consider “how to use this new measure as part of a broader set of care coordination measures applicable to all types of providers.” NQF explained that “CMS [has] agreed to defer use of this particular readmission measure in the new CMS Readmissions Reduction Program until MAP had deliberated and recommended back to CMS its advice on the measure’s optimal use.”
Measure 1789 is described on NQF’s website, available by clicking here. Documentation related to the providers’ appeal (see Attachment A), including AHA’s January 20, 2012 letter to NQF regarding Measure 1789 (see Attachment D), is available by clicking here. The NQF’s June 29, 2012 Press Release announcing the Board’s decision to uphold its endorsement of Measure 1789 is available by clicking here.
Reporter, Susan Banks, Washington, D.C., +1 202 626 2953, sbanks@kslaw.com.
