draft halo comment letter 11 22 10x

November 22, 2010 Donald Berwick, M.D., M.P.H. Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 Dear Dr. Berwick: As the Centers for Medicare & Medicaid Services (CMS) prepares its proposed rule to implement the hospital value-based purchasing (VBP) program, as required by Section 3001 of the Patient Protection and Affordable Care Act of 2010 (ACA), we would like to take this opportunity to comment on several aspects of the program. America’s hospitals are committed to improving the quality and safety of the care provided every day and welcome the opportunity to tie quality measurement to performance-based payments in a VBP program. We look forward to collaborating with CMS on all aspects of VBP, both now and in the future. To that end, we offer CMS a number of suggestions for how to structure the VBP program in a consistent and transparent manner that will accurately assess hospital performance and equitably distribute VBP payments, in order to achieve our shared goal of improved quality and patient outcomes. Our comments focus on the quality measures to be selected, calculation of the performance scores, minimum numbers of cases and measures for participation, distribution of the incentive payments, ...