The American Nurses Association thinks HCFA's proposal to radically update Medicare conditions of participation is a forward-looking idea but worries that hospitals will use this new freedom to further trim nurse staffing and take other shortcuts that will compromise quality of care.
The viewpoint is contained in the association's extensive comments filed Feb. 17 in response to HCFA's proposed regulations revising the conditions for participation, first published Dec. 19 (Jan. 12, p. 12).
Hospitals must meet these conditions set by the government in order to be reimbursed for treating Medicare patients. The ANA is the first major interest group known to have filed comments by the original deadline listed in the Federal Register.
At the request of the American Hospital Association and other groups, the government extended the comment period until April 20.
The AHA is working on getting "member input" and probably won't file its comments until April, an AHA spokeswoman said.
But the nurses already know what they think. They like the basic idea, that federal regulation should move toward an outcomes orientation and away from standards. But they think the state of the art isn't where it needs to be yet.
"Outcomes measurement and evaluation remain at an early stage of development . . . and in some areas no outcomes-focused measures yet exist to substitute for structure- and process-oriented ones," the nine-page letter from ANA Executive Director Argene Carswell said. Therefore, the ANA wants HCFA to retain many of the requirements it proposes to eliminate.
Specifically, the ANA is disappointed that HCFA hasn't put forward any standard performance measures. The association lists existing measures that could be used as determinants of quality, such as nosocomial infection rates, medication errors, numbers of patient falls, bedsores and urinary tract infections.
"Hospital assertions of the private, proprietary nature of patient outcome data" are the main impediment to this kind of quality reporting, the ANA said. The nurses want this information released to regulators and the public.
Perhaps most dear to the ANA's heart, the proposed regulations cite the importance of nurse staffing.
Under the proposed regulations, hospitals would be required to staff in a way that reflects "the volume of patients, patient acuity and intensity of the services provided." They also would be required to make public their methodology for setting staffing levels.
The ANA supports both requirements.