Dorinda West

Regarding QIP scoring for low volume facilities: I believe CMS should consider adjusting the current scoring calculations for low volume facilities. One of my low volume facilities as defined by the CMS rules for bundled payment, has been negatively affected the QIP score due to its low volume of patients. The facility received 15 of a total 30 points due to 1 patient of 13 eligible with a HGB <10. This resulted in zero points for this measure. The facility was awarded 10 points for each of the other 2 measures. In short, this facility will lose 1.5% of their reimbursement for the entire calendar year 2012 because 1 patient in 2010 had a HGB <10. Considering the co morbid conditions of the ESRD patient, this seems completely unreasonable. Of equal concern is the public reporting of the score. Please clarify how the scores will be stated on the Dialysis Facility Compare website as well as the certificate we must post in this facility. I am concerned that the public will see this facility earned only ½ of the points possible, leading to the possible conclusion that this facility’s quality is only ½ as good as it should/could be. Please clarify how this data will be presented to the public. CMS made allowances in the bundled payment rule for low volume facilities providing less than 4,000 treatments annually or approximately 25 patients. It would seem that the same criteria should be followed when looking at quality, or at least some altered calculation for those facilities with eligible patient numbers between 11 and 25.