Collecting the risk factor data for the efficiency measures is too burdensome.

To address the concerns with burden, Leapfrog has ensured that the risk factor data for the efficiency measures is collectible from administrative data sources.  No chart abstraction should be required.     

Postpone the efficiency measures until the severity-adjustment model is made available for public consumption and comment.

Readmission rate within 14/15 days is not a common indicator, most hospitals use 30 days as their indicator.

A readmission rate within 14 days is used in the efficiency models to improve the likelihood that the readmission is related to the hospitalization.  Using a 30-day readmission rate reduces the likelihood that the readmission is linked to the previous hospitalization, and increases the potential for other community factors or unrelated conditions to impact the patient thereby resulting in the readmission.

Leapfrog is too far ahead on Hospital Acquired Conditions; CMS has an October 1, 2008 implementation date for payment reductions.

Since CMS announced they were no longer going to reimburse hospitals for certain hospital-acquired conditions, private insurers (UnitedHealth Group, CIGNA, and WellPoint) have followed CMS’s lead and have announced similar plans. Leapfrog believes these announcements reinforce the need to have this information transparent and available to consumers and purchasers. Leapfrog is asking hospitals to report on just two of the six hospital-acquired conditions from the CMS list in this year’s survey.

No risk adjustment for the Hospital Acquired Condition measures.

These conditions are part of the set of The National Quality Forum’s “28 Reportable Events” and as such should not be occurring in hospitals.  To risk adjust would suggest that these events are expected.    

The EBHR “Survival Predictor” is not clearly defined and needs to be postponed until available for public comment.

The Common Acute Conditions process measures duplicate what is already being reported to CMS

We have attempted to negotiate on data before; however, generally the availability of the data file to others is significantly later than the data available to the hospital in their reports from CMS.

Pneumonia -  The Joint Commission has replaced the measure “Initial Antibiotic Received Within 4 Hours of Hospital Arrival” mid-year with the measure “Initial Antibiotic Received Within 6 Hours of Hospital Arrival”, which is endorsed by NQF.

Leapfrog has updated the survey to reflect this change in the measure.  As the measure was changed mid-year, hospitals can elect to use the original measure (within 4 hours) when reporting to the 2008 survey.

Glad to see that EBHR-Surgeon Volume was dropped from the survey.

Leapfrog’s philosophy is that outcome measures are the preferred measures to use where possible.  Evidence shows that the “survival predictor” model that will be introduced in the 2008 survey does a better job of predicting a patient’s outcome for a procedure than surgeon volume.  

With more minimally invasive surgeries being done, reevaluate the CABG hospital volume threshold (450 cases/yr).

While Leapfrog understands that more minimally invasive cardiac surgery is being done in lieu of CABGs, the evidence still remains that outcomes for patients that have traditional, more invasive CABG surgery are significantly better in hospitals that perform 450 or more of those procedures per year.  We also understand that many hospitals that had not been performing CABG surgery in the past are now performing it—this is counter to the desired trend where the most experienced hospitals provide the surgery.

Improve definition of never events; provide distinction between preventable and non-preventable events.

Leapfrog’s Never Events policy is based on NQF’s list of 28 Serious Reportable Events (Never Events), which does not distinguish between preventable and non-preventable events.  Leapfrog’s policy requirements (root cause analysis; report to external agency; apologize to patient; do not charge) is applicable and appropriate for all of these serious reportable events.

Pleased to see the Safe Practices section shortened.

The survey should require data validation; there is no quality control of input.

While Leapfrog does not actively audit survey responses, a strong majority of the questions asked in the survey are auditable.  In addition, Leapfrog reports outcome measures, volume measures and process measures that are audited by other parties (including groups like The Joint Commission, CMS, States (CA, NY, NJ, MA, PA), and the NNECSG).  Leapfrog also made revisions to the 2008 Safe Practices section of the survey to ensure that questions asked are more straight-forward, less open to interpretation, and can be documented in an audit process.  As concerns arise with a hospital’s responses, Leapfrog does reach out to the hospital to ensure they clearly understand the intent of the questions and provides them the opportunity to update their answers.  We also maintain the right to remove a hospital’s answers from our website.