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Document ID: CMS-2011-0003-0012
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: 80bd30dc
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This is comment on Proposed Rule

Medicare Program: Hospital Inpatient Value-Based Purchasing Program

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Object to the inclusion of AHRQ PSI #4, Death among Surgical Inpatients with Serious Treatable Complications in the VBP rule. I feel this doesn't account for patients who are admitted with sepsis, or acute illness, on multiple vasopressors with multi system organ failure. Often times, the patient will be taken for an exploratory lap to see if the belly is the cause of the sepsis. Subsequently, they are coded as a "surgical patient" and fall into this category, even though nothing was found in exploration in the OR, and the surgery didn't contribute to their death. Upon our own internal review, we have approximately 25% of these cases that fall into this bucket. Without an exclusion criteria based upon ASA category, I don't suggest this indicator be utilized for quality metrics.