The AHA urges significant changes to quality provisions of proposed CMS CY09 outpatient rule

In a letter to the Center for Medicare and Medicaid Services (CMS), the American Hospital Association (AHA) expressed its serious concern with aspects of the CMS proposed CY 2009 Outpatient Rule, noting that the 4 new measures of medical imaging efficiency have neither been endorsed by the National Quality Forum (NQF) nor adopted by the Hospital Quality Alliance (HQA). In the past, measures required to be reported as a condition of CMS payment have been both endorsed by NQF and adopted by HQA.

According to the AHA letter , measures of outpatient imaging efficiency were still in the early stages of NQF endorsement, and final endorsement isn’t expected until, at best, October 31, 2008, one day before the final rule is expected to be published. AHA does not believe CMS provided sufficient detailed information about the 4 outpatient imaging measures, and thus it is not yet possible for outside organizations to provide thorough review and comment.

Proposed changes to the Hospital Outpatient Prospective Payment System (OPPS) for CY2009 were published in the July 3, 2008, Federal Register and are open for public comment until September 2, 2008. The changes are outlined in the proposed rule, CMS-1404-P (PDF) , which can be viewed and downloaded from the Hospital Outpatient Regulation and Notices listed on the CMS website. The proposed OPPS changes would be applicable to services furnished on or after January 1, 2009. Details regarding the Reporting Hospital Outpatient Quality Data for Annual Payment Update (RHQDAPU) program begin on page 478 of the downloadable file. (SOURCES: AHA News Now ,, August 28, 2008; QualityNet ,, accessed August 30, 2008)