Kusserow on Compliance: OIG Report on Quality Improvement Organizations

Right after the first of the year, the HHS Office of Inspector General (OIG) released a report on a study of Quality Improvement Organizations (QIOs) to determine: (1) the extent and manner in which hospitals participated in QIO projects in 2013; and (2) the extent to which QIOs’ projects in hospitals overlapped with projects offered by other entities. Past work by the OIG and others raised concerns about QIOs, including duplication of other quality improvement efforts. Between 2011 and 2014, CMS paid QIOs about $1.6 billion to improve health care for Medicare beneficiaries. During this time, CMS also spent nearly $500 million on two new quality improvement efforts, Hospital Engagement Networks (HENs) and the Community-Based Care Transitions Program (CCTP). Given QIOs’ new five-year, $4 billion contract and the importance of CMS’s quality improvement objectives, it is crucial that CMS coordinate its resources to avoid duplication among its quality improvement efforts.

The OIG sent a questionnaire to a random sample of 410 Medicare hospitals asking whether they worked with QIOs or other quality improvement entities in 2013 and received a weighted response rate of 93 percent. After initial analysis of results, the OIG conducted site visits at three hospitals in two states and QIOs representing four states.

The OIG found over half of hospitals participated with QIOs on quality improvement projects and all hospitals participating in the survey reported receiving benefits by working with QIOs. Eight out of 10 participating hospitals also worked with other federally funded entities on the same topics as QIOs. Most participating hospitals also worked with non-federal entities on the same topics as QIOs. Data problems and timing of other CMS quality improvement efforts hampered QIOs’ ability to target eligible hospitals and avoid duplicating those efforts. QIOs reported problems in key CMS data for recruiting hospitals for infection and readmissions projects. QIOs were already recruiting hospitals when CMS awarded HEN contracts and the CCTP agreements.

Report Findings

  1. Fifty-five percent of hospitals worked with QIOs on quality improvement projects;
  2. All participating hospitals reported receiving benefits by working with QIOs;
  3. Eighty percent of hospitals worked with other federally funded entities on the same topics as QIOs;
  4. QIOs’ ability to target eligible hospitals and avoid duplicating efforts was hampered by data problems and the timing of other CMS quality improvement efforts; and
  5. QIOs reported issues in CMS data for recruiting hospitals for infection and readmissions projects.

Recommendations to CMS

The overlap among CMS’s quality improvement efforts raises concerns about duplication of efforts and makes it difficult to attribute quality improvements to any one effort. The OIG recommended CMS (a) take additional steps to coordinate, and reduce overlap between, the QIO program and CMS’s other quality improvement efforts; and (b) determine the relative contribution of each of its quality improvement efforts. CMS concurred with these recommendations.

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2015 Strategic Management Services, LLC. Published with permission.