QA and PI requirement at the forefront

You must show sustained improvement

The role of quality in Medicare’s current conditions of participation (COPs) is outdated: "Find the problem, fix it, end of story." It doesn’t involve self-improvement, benchmarking yourself against other organizations, or using measures to constantly assess yourself.

At a minimum, the new proposed quality assessment and performance improvement (QA and PI) program COP requires that a hospital annually conduct a number of successful improvement activities in proportion to the scope and complexity of the hospital’s program. The success of the activity is measured in terms of demonstrated sustained improvement over time. A precise explanation of what is expected of each hospital will be in the final rules, but these are among the possible alternatives outlined in the proposal.

1. A hospital could be required to engage in a specific number of improvement projects equal to not less than one project per 1,000 patient discharges.

2. A hospital could be required to engage in a minimum set number of projects (for example, five) that are hospitalwide and most broadly affect patient outcomes and satisfaction.

3. A hospital could be required to engage in a minimum set number of projects (for example, five) that are not hospitalwide, but that are developed and implemented in various areas of the hospital’s range of care and services. For example, one project might reduce waiting time in the emergency room, and another might focus on improving the accuracy of medication administration.

4. A hospital could be required to engage in a minimum number of projects based on bed size, rather than discharges. For example, there might be eight projects in a 600-bed hospital, or two in a 50-bed hospital.

5. Rather than requiring a minimum number of projects, a hospital could be required to demonstrate to the PRO or survey agency what projects it is doing and what progress is being achieved.

6. Again, rather than specifying a minimum number of projects, a hospital could be required to establish a minimum set of types of projects that must be done. For example, projects might be hospital operational processes that are predictive of positive outcomes, such as infection control measures, or condition-specific projects that improve certain clinical outcomes, such as emergency room responses to heart attack patients.