Tuesday, August 18, 2009

Society of Critical Care Medicine P4P implementation guidelines

This appears in the September issue of Critical Care Medicine Journal on page 2625. Mostly makes sense, but voluntary participation? Opting out not affecting economics? What's the point? Somewhat self-serving in other points too.

Society of Critical Care Medicine pay-for-performance implementation guidelines

The goal of a P4P program is to improve patient care.

Quality measures must be evidence-based and be accurate indicators of patient care and outcomes.

Quality measures must be developed, maintained, and reviewed in an open and transparent process.

Quality measures must be under the direct control of the intensivist physician.

Before implementation, P4P programs must be pilot-tested to ensure valid data collection and accuracy.

Performance measures involving outcomes (i.e., mortality, morbidity) must be risk adjusted.

P4P programs must demonstrate improved quality of patient care as a result of implementation for outcome measures.

Quality measures must be reviewed at least every 2 years.

The best programs would also provide expert opinion and discussion with suggestions for improvement.

Physician participation is voluntary.

Physicians must be able to opt-in or opt-out of a P4P program.

Opting-out must not have negative economic consequences.

Physician participation in P4P must not be linked to participation in other health plans or governmental programs.

Programs must be phased in to allow physician participation.

Physicians must be notified at least 6 months in advance, in writing, regarding new P4P opportunities, changes in existing programs, or rewards.

Data collecting must be simple and valid.

Patient privacy and security of all data must be protected at all times consistent with the Health Insurance Portability and Accountability Act.

Data collection and reporting must be simple and reliable.

Audit systems must be implemented to ensure accuracy of data.

Physicians must be reimbursed for any added costs incurred as a result of participating in the program.

Performance data should be aggregated and analyzed by an independent entity, audited by an independent third party, and reviewed by the reporting physician or group with all costs paid for by the program.

Feedback of performance data should be provided monthly and compared against historical norms, peers, and performance targets in a clear and easy-to-understand format.

Confidentiality and public reporting.

Physicians should be assessed in groups or across systems rather than individually, if possible.

Physicians must be able to see preliminary ratings and given an opportunity to improve before ratings are publicly released.

There must be a formal appeal process before public release of ratings.

Results of P4P programs must not be used for health plan credentialing, hospital privileges, licensure, or board certification.

Individual physician P4P data must remain confidential and nondiscoverable in legal proceedings.

Use of IT should be encouraged, but not required for participation in P4P programs.

Programs must not favor physician practices by capabilities in IT.

Programs must not require practices to purchase health plan-specific IT programs.

Programs must be designed to minimize financial and IT barriers to physician participation.

Programs must provide tools to facilitate participation.

Programs must provide funds to encourage the use of IT.

P4P programs should be based on rewards and not penalties.

P4P programs should utilize new money funded by using a portion of the projected health plan savings.

There should be no reduction in existing fees paid to physicians as a result of implementing a P4P program.

P4P programs must provide additional incentives to purchase and utilize IT and electronic medical records.

Rewards must be greater than the costs associated with participation.

Rewards should be of a significant magnitude to encourage desired behaviors and support continuous improvement.

Rewards should be provided for both achieving program goals and performance improvement.

Ranking with other physicians participating in the program or groups should not occur, and rewards must not be based on rank.

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