Public and private reporting have been measures to force hospitals to strengthen patient safety efforts for a while now. In many ways, these rules are a result of poor patient safety and infection control practices that have historically led to high volumes of patient morbidity and mortality.
The 2008 Centers for Medicare and Medicaid Services (CMS) “no pay” rule
for hospital-acquired conditions is the most detrimental for healthcare facilities in terms of the risk to their reimbursement for patient care. Even at a state level, there are a variety of reporting requirements
to public health departments regarding outbreaks within a healthcare facility.
Due to these reporting requirements, especially for reimbursement, hospitals are forced to not only perform surveillance, but also address hospital-acquired conditions from an administrative level. Although federal and state reporting occurs, there are also private accreditation surveys and annual reports that hospitals put forth. Hospital accreditation with organizations such as The Joint Commission or Det Norske Veritas (DNV) is a way for healthcare facilities to bring prestige to their programs and practices. These kinds of accreditation surveys aren’t required by law like that of federal and state, but hospitals capitalize on the prestige of these certifications.
Now, a new CMS proposal is attempting to take reporting to a groundbreaking new level. Previously, private healthcare accreditation surveys were just that—private. However, the new proposal from CMS is looking to require that these private accreditors make public the problems and negative findings they report during their hospital surveys. The reason for this new proposal is not only because roughly 90% of hospitals are directly overseen by private accreditors, but also because there is growing concern that their surveys fail to find significant problems and patient safety risks within facilities.
Indeed, it was recently reported
that when state officials reviewed 103 acute-care hospitals recently inspected by an accreditor, 39 of the observed 41 serious deficiencies were completely missed by the accreditor survey. When a CMS inspection (performed by state public health officials) finds serious deficiencies, it creates a condition in which the hospital is given a certain period of time to fix the issue to avoid losing funding. Accreditor surveys are unannounced in most cases, usually once every two to three years, and rarely result in any punitive action.
Having experienced unannounced visits from both CMS and accreditation surveyors, I’d rather take the accreditor. They ultimately depend upon hospitals wanting their stamp of approval, which as you can imagine, creates an environment rich for bias.
The American Hospital Association supports the public reporting of accreditor surveys; however, many are highlighting the need for such reports to be easily understandable and truly offer transparency. Public reporting is only as effective as it can be understood. Many of the federal or accreditation requirements can be complex and only truly understood by someone in healthcare. The point of public reporting is to increase transparency, which means that these reports will need to be presented in a manner that will allow anyone to understand the significance of the findings. Current findings that are made publicly available from private accreditors are extremely vague and fail to describe any deficiencies or patient harm events observed. Full disclosure reporting of these accreditor surveys and findings may be just the thing to force both parties to increase transparency and patient safety efforts.
And, let’s not forget another component to consider; the prestigious hospital comparison rankings like Leapfrog and US News & World Report. The annual survey to become a center of excellence for US News & World Report has little validation processes, and increasingly impossible expectations. Over the years, the infection control baseline values to make the prestigious titles have become so astoundingly low that I often wonder if there is a culture of false reporting that is snowballing. Data from the previous year is reported to each hospital, which means they are able to see the rates of the top hospitals in certain categories, thus creating a new benchmark for excellence. What is concerning is that many hospitals, in efforts to make the top ten or win awards, will do whatever it takes to meet or exceed those benchmarks from the previous year. As the rates and benchmarks for success get unnaturally lower, it gives the impression that these unrealistic rates are attainable.
That is a different story for a different day though. Should the proposal pass, it will be necessary to ensure the reports are truly accessible and useful for the public to aid in their healthcare decisions. Only time will tell if this will come to pass.