NHHA VBP comment letter 030811

March 8, 2011 Donald Berwick, M.D. Administrator Centers for Medicare and Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 Re: Hospital Value-Based Purchasing Program Proposed Rule for FFY 2013 Dear Dr. Berwick: The New Hampshire Hospital Association (NHHA), on behalf of our 26 member hospitals, appreciates this opportunity to comment on the proposed rule for the inpatient hospital Value-Based Purchasing (VBP) Program. We support the general direction of CMS’ proposal including weighting of the HCAHPS measures at the proposed level of 30%, which we believe serves to give proper due importance to patients’ experience during their hospital stay. We also support the use of consistency points that reward hospitals for performing well on all dimensions of the patient care experience. Comments on other aspects of the proposed rule are below: PERFORMANCE AND BASELINE PERIODS In the proposed rule for FFY 2013, CMS is proposing a 9-month performance period of July 1, 2011 through March 31, 2012. NHHA believes that all VBP measures must have useable, CMS-reported data for a full 12-month baseline and a full 12-month performance period. We support the proposed use of 9-month baseline and performance periods for the first year only. In subsequent years, however, NHHA strongly recommends that the VBP performance and baseline periods each be comprised of at least 12 months of ...