In Pursuit Of Hospital Quality: Creating Effective Performance Measures And Transparency In Health Care

From: Health Affairs Blog

Charles Kahn


Well-honed clinical and performance measurement now and “big data” analytics in time should drive quality improvement, value purchasing, and meaningful transparency. We must assure patients and their loved ones that when they choose a hospital or find themselves in an emergency room, that every facility is considered, as Garrison Keillor would say, “above average.”

Bruce Levinson says:

One of the Data Quality Act’s requirements is that information disseminated by CMS and other agencies needs to be useful to its intended users. Since the agency’s measures of health care quality have the potential to assist better decision making by consumers and health care providers, biased, arbitrary or otherwise unreliable data has potential to lead to poor choices and adverse health outcomes.

If CMS’s quality measures are going to achieve their promise, and if transparency is going to be more than a buzz word, the agency’s quality measures will need to be developed and vetted through a rulemaking process consistent with the requirements, including the peer review requirements, of the Data Quality Act, the Paperwork Reduction Act and the other “good government” laws that regulate the regulatory process.

Unfortunately, CMS has apparently been violating both the Medicare Act and the Administrative Procedure Act by not going through the required processes for developing health care quality measures used in determining Medicare payments. The Center for Regulatory Effectiveness has written to CMS discussing the steps the agency needs to take to ensure that its rating programs achieve their goals. In the letter, CRE asks that CMS notify us of its responses to our specific points and to discuss any actions it will take to ensure and maximize the quality of its ratings. CRE’s letter to CMS is available here,

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