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Document ID: CMS-2011-0003-0011
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: January 26 2011, at 12:00 AM Eastern Standard Time
Date Posted: February 3 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: January 13 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: March 8 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80bd30a8
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This is comment on Proposed Rule

Medicare Program: Hospital Inpatient Value-Based Purchasing Program

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Looking to the future for using electronic submission of measures for the values based purchasing program, it appears that there is a misalignment in one of the potential future measures. This measure is the "Median time from admit decision to time of departure from ED for ED patients." The HITSP April 30, 2010 V1.1 manual states that data element 1.3.6.1.4.1.33895.1.4.0.2, Admit Decision Time to ED Departure Time will use the Order to Admit Date/Time (data elements 2.1.2.27, 2.2.2.16, 16.14). However in the current Specifications Manual for National Inpatient Quality Measures V3.3, the alpha dictionary lists Admit Orders Date (and Admit Orders Time) in the Exclusion Guidelines for Abstraction. The concern is that the meaningful use measure will use admit order date / time to calculate the median time, however the abstracted measure suggests that the admit order date/time is not a valid source for this data element. Guidance regarding what is the true data element to use for the calculation of this measure is appreciated.