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Patient safety and quality improvement federal activities

Patient Safety

The AMA continues to lead physicians' efforts to measurably improve patient safety and quality of care by:

  • Working to ensure the proper implementation of the Patient Safety and Quality Improvement Act (Patient Safety law; Public Law 109-41 109th Congress), including voluntary reporting systems with strong confidentiality protections.
  • Continuing to convene the highly respected Physician Consortium for Performance Improvement to develop evidence-based performance measures to improve the quality of care.

The final rule on the Patient Safety law that was issued by HHS in November 2008, captures the intent of the Patient Safety Act; to create a voluntary reporting program through which health care providers can share information relating to patient safety events with patient safety organizations (PSOs) on a privileged and confidential basis in order to improve patient safety and the quality of care. The final rule reiterates that this voluntary program is not federally funded but sets forth the framework by which health care providers may voluntarily report information to PSOs, on a privileged and confidential basis, for the collection and analysis of patient safety events. The final rule indicates that the Agency for Healthcare Research and Quality (AHRQ) will implement and oversee the process for certification and listing of PSOs and that the Office of Civil Rights (OCR) will investigate and enforce compliance with the confidentiality requirements.

Since 2008, the AMA has been making recommendations on the federal framework for physicians, hospitals, and other health care professionals and entities to voluntarily report patient safety work product to PSOs on a privileged and confidential basis. Read the letters:

AMA comments to ONC regarding ONC’s Health IT Patient Safety Plan, February 1, 2013

AMA comments on AHRQ proposed prototype Consumer Reporting System for Patient Safety Events, October 31, 2012

AMA comments to AHRQ on Common Format-Readmissions Version 0.1 Beta, September 14, 2012

AMA comments to ONC regarding the need to further study and monitor the impact of health IT on patient safety, March 1, 2012.

AMA comments to AHRQ on Common Formats—Device or Medical/Surgical Supply, including a Health Information Technology (HIT) Device, November 16, 2010

AMA comments to AHRQ on Common Formats Version 1.0, October 14, 2009

AMA comments to AHRQ on Patient Safety and Quality Improvement Proposed Rule, April 11, 2008

It is important for physicians to know that, prior to submitting information to an entity that claims to be a PSO, they should always verify that the entity is currently listed on AHRQ's Web page.If a physician submits information to an entity that is not listed on AHRQ’s Web page, the confidentiality and privilege protections of the Patient Safety Act will not apply. In addition, never submit information to a PSO listed before its effective listing date. For more information on PSOs, please check AHRQ's Web page.

To help physicians optimize the quality and safety of patient care, the AMA developed the "Physician's Guide to Patient Safety Organizations." The guide to PSOs assists physicians in voluntary reporting of adverse safety events, and is full of practical information, including a glossary, a reporting checklist and a work-flow model. It also includes an analysis of patient safety evaluation systems and the Patient Safety law, which created PSOs. Learn more about the AMA’s patient safety activities.

HHS Partnership for Patients Initiative
On April 12, 2011, the Department of Health and Human Services (HHS) launched a new patient safety initiative entitled, "Partnership for Patients: Better Care, Lower Costs." According to HHS, this initiative will seek to accelerate the reduction of hospital-acquired conditions with a goal of reducing them by 40 percent between 2010 and the end of 2013. The initiative will also seek to decrease preventable hospital readmissions within 30 days of discharge, so that by 2013 readmissions would be reduced by 20 percent compared to 2010. Specifically, the federal government will provide financial resources for technical support to physicians, nurses, and other clinicians working in and out of hospitals to test large scale implementation of care delivery models that make patient care safe, and to support effective transitions of patients from hospitals to other settings. The Center for Medicare and Medicaid Innovation (CMMI) will make $500 million available for the care transition grant program and $500 million for training and support to address hospital-acquired conditions. Participation in this initiative is voluntary, and penalties will not be applied to participants if the percentages are not met. The AMA is a supporter of the initiative's Pledge. Additional information regarding this initiative can be found on HHS' HealthCare.gov website. Learn more about the Community-based Care Transitions Program and its funding opportunities.

Quality Improvement

The AMA is committed to quality improvement and supports innovative efforts to provide high quality, cost-effective care to patients. The AMA is the national leader in creating tools to help physicians provide the highest quality care to patients. In recognition of physicians’ professional responsibility to provide quality health care, the AMA began developing physician performance measures in 1998, and in 2000 convened the Physician Consortium for Performance Improvement.

In order for any quality physician program to be effective, it is vital that certain elements be integral to the program, including such factors as: physician development of quality measures; appropriate use of quality data; effective educational efforts to help ensure that physicians can easily and properly report data under the program; the ability for physicians to verify the data that is used in developing a physician rating under a quality program; physician appeal rights with regard to various aspects of the program; and a stable physician payment structure.

Many AMA officers and staff frequently participate in quality discussions through the National Quality Forum (NQF), Quality Alliance Steering Committee (QASC), AQA Alliance (formally the Ambulatory Care Quality Alliance), Agency for Health Care Research and Quality (AHRQ), National Committee for Quality Assurance (NCQA), and the Institute on Medicine (IOM). Participation includes face-to-face meetings, weekly conference calls to discuss issues of quality measurement (cost of care, episodes, care coordination, and efficiency), data aggregation, and health care price transparency, among others.

For more detailed information, below are various AMA communications with the Administration and Congress regarding ongoing and proposed quality programs and initiatives.

January 27, 2014, AMA comments to the NQF on the Measure Applications Partnership (MAP’s) Draft Pre-Rulemaking Report

October 25, 2011, the AMA and 38 medical specialty societies sent a letter to the National Quality Forum (NQF), seeking improvements in its quality measure endorsement processes.

Hospital Acquired Conditions (HACs) and Healthcare Associated Infections (HAIs)
Physician Quality Reporting System (PQRS)

Despite strong opposition from the physician community, CMS finalized Calendar Year 2013 as the performance period for the 2015 PQRS penalties. Therefore, if CMS determines that an eligible professional or group practice has not satisfactorily reported through one of the finalized 2013 reporting options for avoiding a payment adjustment or qualifying for a payment incentive for the Jan. 1, 2013 through Dec. 31, 2013 reporting period, the fee schedule amount for services furnished by the participating professional or group practice during 2015 would be 98.5 percent of the fee schedule amount that would otherwise apply to such services.

CMS has established different reporting requirements for individual physician and nonphysician providers, as well as group practices for participating in the 2013 PQRS program. Participation requirements to qualify for a payment incentive differ from requirements for avoiding a payment penalty. However, qualifying for an incentive allows the individual or group practice to avoid the payment adjustment. In addition, those physician practices who are comprised of 100 or more eligible professionals (EPs) must self-nominate by Oct. 15, 2013 if they are to avoid application of the value based payment modifier.

For more information regarding the 2013 PQRS program, please visit the AMA's Clinical Quality web site.

CMS 2010 Reporting Experience: Including Trends 2007-2011 on the PQRS and eRx Incentive Programs

AMA comment letters regarding Medicare physician quality measurement reporting:

February 9, 2016, sign-on letter to CMS expressing concerns about the 2016 PQRS feedback and informal review request processes

May 2, 2014, AMA letter urging CMS to reinstate the administrative claims option for PQRS, and adopt a PQRS exemption for achieving Meaningful Use.

March 28, 2012, AMA-generated sign-on letter to CMS voicing concerns about simultaneous implementation of multiple programs.

February 25, 2011, AMA statement to CMS regarding implementation of the 2012 Physicians Quality Reporting System (PQRS).

August 24, 2010 comment letter to CMS regarding the proposed payment policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2011 (PQRS discussion found on pages 9-22).

April 30, 2010 letter to CMS regarding proposed changes to the percentage threshold for determining successful PQRI participation.

August 31, 2009 comment letter to CMS regarding CY2010 Medicare physician fee schedule proposed rule (PQRI discussion found on pages 6-12).

November 7, 2008 letter to CMS Administrator regarding necessary changes to the PQRI program.

October 29, 2008 Press Release on results from AMA sponsored PQRI survey.

August 29, 2008 comment letter to CMS regarding CY2009 Medicare physician fee schedule proposed rule (PQRI discussion found on pages 4-16).

Profession's Commitment to Quality in Health Care

April 1, 2009, Action Plan to President Obama and the Chairs and Ranking Members of the House and Senate committees of jurisdiction regarding steps the medical profession will undertake in the coming months to engage and support physicians in using patient-centered measures and health information technology that empowers them to provide high-quality, cost-effective care across the continuum of care. These steps include a commitment to: education, evidence-based clinical guidelines, development of quality measures, and Board Certification and Maintenance of Certification. This Action Plan is an attempt to clearly articulate what the medical profession will do over the coming year to promote the profession’s vision for quality improvement articulated in the February 24 letter referenced below.

February 24, 2009, joint letter to President Obama and the Chairs and Ranking Members of the House and Senate committees of jurisdiction on medicine's commitment and vision for improving patient outcomes and health care system efficiency.

Quality Improvement Organizations (QIOs)
Public Reporting and Data Release
Value-Based Purchasing (VBP)