The PULSE Coalition for Support and Healthcare Reform



To date, HR 676 appears to be the only logical way to effectively reduce medical errors and transform the healthcare system into one that is safe, efficent and sustainable.   Many who survive medical errors will find themselves permanently disabled and no longer able to work.  They then lose benefits and are cannot afford insurance due to a pre existing condition that is no fault of their own.  Less then 5% of these people ever sue, which leaves them forced to exhaust all of their resources before they are eligible for public assistance.  Care of the disabled is very expensive, and many are not able to get Social Security for years after the iatrogenic injury.  This is just one component of why we might need Single Payer in the USA.  Another is that with Single Payer, safer healthcare is a benefit to all as follow up care for medical error will no longer be profitable.   It will be easier to report and track errors and learn from them.  CMS has led the way with no pay rules for medicare and medicaid patients who are befallen by certain preventable conditions.   The patients cannot be billed.  This must happen universally before the syetem will change, single payer is the only way for this to happen.   Below you will find detailed information on CMS rules.




For Immediate Release: Monday, August 04, 2008
Contact: CMS Office of Public Affairs


When you enter the hospital for treatment of one medical problem, you dont expect to leave with additional injuries, infections, or other serious conditions that occur during the course of your stay.  Although some of these complications may not be avoidable, too often patients suffer from injuries or illnesses that could have been prevented if the hospital had taken proper precautions.


As part of its commitment to improve the quality of care you receive during a hospital stay, and to make sure that Medicare only pays for items and services that are reasonable and necessary, Medicare is taking new steps to make hospitals safer by adopting payment policies that will encourage hospitals to 1) reduce the likelihood of hospital-acquired conditions like certain infections, advanced bed sores, or fractures; and 2) reduce preventable medical errors, like performing surgery on the wrong body part, that should never happen.



Hospital-Acquired Conditions


What they are:Medicare has selected conditions that are reasonably preventable by following evidence-based guidelines and that are either costly or common.  These conditions include:


  • Foreign object (such as a sponge or needle) inadvertently left in patients after surgery
  • Air embolism - an air bubble that enters the blood stream and can obstruct the flow of blood to the brain and vital organs
  • Transfusion with the wrong type of blood
  • Severe pressure ulcers C deterioration of the skin, due to the patient staying in one position too long, that has progressed to the point that tissue under the skin is affected (Stage III), or that has become so deep that there is damage to the muscle and bone, and sometimes tendons and joints (Stage IV)


  • Falls and trauma:
  • Fracture
  • Joint dislocation
  • Head injury
  • Crushing injury
  • Burn
  • Electric shock
  • Catheter-associated urinary tract infection (UTI)
  • Vascular catheter-associated infection
  • Manifestations of poor control of blood sugar levels
  • Surgical site infection following coronary artery bypass graft (CABG)
  • Surgical site infection following certain orthopedic procedures
  • Surgical site infection following bariatric surgery for obesity
  • Deep vein thrombosis (a blood clot in a major vein) and pulmonary embolism (blockage in the lungs) following certain orthopedic procedures


What Medicare is doing: Since October 1, 2007, hospitals have been required to report on their Medicare claims if any of the first eight selected conditions were present at the time the patient was admitted to the hospital, and beginning October 1, 2008, will have to report on the remaining conditions as well.  If at discharge, there is a selected condition that was either not identified by the hospital as present on admission, or could not be identified based on data and clinical judgment at admission, it is considered hospital-acquired.  To encourage hospitals to avoid hospital-acquired conditions, beginning October 1, 2008, Medicare will no longer pay hospitals at a higher rate for the increased costs of care that result when a patient is harmed by one of the listed conditions if it was hospital-acquired.  Medicare prohibits the hospital from billing the beneficiary for the difference between the lower and higher payment rates.


Medicare will pay for physician and other covered items or services that are needed to treat the hospital-acquired condition, including the costs of post-acute care that would not have been needed for the patients initial medical problem, but are needed because of the hospital-acquired condition.



Medical Errors That Should Never Happen (Never Events)


What they are:  There are some events that should never happen in a hospital.  When they do occur, they can cause serious injury or death to the patient.  The National Quality Forum (NQF) has defined these as Serious Reportable Adverse Events, commonly referred to as never events.  These events are also likely to be very costly both for the beneficiary and the Medicare program.  Some examples of never events include:


  • Surgery on a wrong body part
  • Surgery on a wrong patient
  • Wrong surgery on a patient


What Medicare is doing:  In most cases, Medicare pays only for items or services that are reasonable and necessary for the treatment of the patients condition, or certain preventive services required by the Medicare law.  For the three wrong surgeries listed as examples above, Medicare is opening a National Coverage Decision process to look at how to ensure that patients get necessary care, but that the Medicare program would not pay the doctor and the hospital for an erroneous surgery.





The most important impact for you, and those who care for you when you are ill or incapacitated, is that you should receive higher quality care during your hospital stay.  With these Medicare payment rules, hospitals have additional incentives to make more thorough assessments of your condition at admission, to have systems in place to prevent adverse events from occurring during your stay, and to prevent you from undergoing surgery that you do not need and that may result in permanent injury.  To the extent that these policies succeed in reducing the frequency of hospital-acquired conditions and wrong site surgeries, you, as both a patient and a taxpayer, should pay less, while getting better outcomes.





The quality of the care you get in the hospital is important to your health.  Hospitals should follow accepted standards of practice to prevent hospital acquired-conditions and Never Events.  If you have concerns about the quality of care you received while in the hospital, call the Quality Improvement Organization in your state.  Call 1-800-MEDICARE (1-800-633-4227) to get the telephone number.  TTY users should call 1-877-486-2048.


For information about the quality of care provided by hospitals in your area, see the Hospital Compare feature on our Web site at


For Immediate Release: Thursday, August 14, 2008
Contact: CMS Office of Public Affairs


The Centers for Medicare & Medicaid Services (CMS) announced today that all physician groups participating in the Physician Group Practice (PGP) Demonstration improved the quality of care delivered to patients with congestive heart failure, coronary artery disease, and diabetes mellitus during performance year 2 of the demonstration. 


As a result, the 10 groups earned $16.7 million in incentive payments under the demonstration that rewards health care providers for improving health outcomes and coordinating the overall health care needs of Medicare patients assigned to the groups. 


We are paying for better outcomes and we are getting higher quality and more value for the Medicare dollar, said Kerry Weems, acting administrator of CMS.  And these results show that by working in collaboration with the physician groups on new and innovative ways to reimburse for high quality care, we are on the right track to find a better way to pay physicians.


All 10 of the participating physician groups achieved benchmark or target performance on at least 25 out of 27 quality markers for patients with diabetes, coronary artery disease and congestive heart failure. 


The groups are:


                    Billings Clinic, Billings, Mont.

                    Dartmouth-Hitchcock Clinic, Bedford, N.H.

                    The Everett Clinic, Everett, Wash.

                    Forsyth Medical Group, Winston-Salem, N.C.

                    Geisinger Clinic, Danville, Pa.

                    Marshfield Clinic, Marshfield, Wis.

                    Middlesex Health System, Middletown, Conn.

                    Park Nicollet Health Services, St. Louis Park, Minn.

                    St. Johns Health System, Springfield, Mo.

                    University of Michigan Faculty Group Practice, Ann Arbor, Mich.


Five of the physician groups -- Forsyth Medical Group, Geisinger Clinic, Marshfield Clinic, St. Johns Health System, and the University of Michigan Faculty Group Practice achieved benchmark quality performance on all 27 quality measures. 


This demonstration is one of CMS value-based purchasing (VBP) initiatives.  The goal of VBP is to tie Medicare payments to performance on health care cost and quality measures. VBP is part of CMS drive to transform Medicare from a passive payer to an active purchaser of higher quality, more efficient health care. 


A related CMS physician VBP effort is the Physician Quality Reporting Initiative (PQRI), which uses a pay-for-reporting approach.  Under the PQRI, physicians and other health care professionals can earn incentive payments for reporting measurement data about the quality of care they provide to Medicare patients


CMS is also starting development of a Physician VBP Plan for moving from the PQRI pay-for-reporting approach to a performance-based approach for Medicare physician payments.  The experience that CMS has gained from the PGP Demonstration will be considered in developing the performance-based payment plan.


The 10 physician groups participating in the PGP Demonstration agreed to place their PQRI incentive payments at risk for performance on the 27 quality measures reported under the demonstration.  All physician groups received at least 96 percent of their PQRI incentive payments, with five groups earning 100 percent of their incentive payments. A total of $2.9 million in PQRI incentive payments was paid out to the 10 groups under the demonstration.   


The groups also improved the quality of care delivered to Medicare beneficiaries on the chronic conditions measured.  Physician groups increased their quality scores an average of 9 percentage points across the diabetes mellitus measures, 11 percentage points across the heart failure measures, and 5 percentage points across the coronary artery disease measures. 


These groups achieved outstanding levels of performance by having clinical champions (physicians or nurses who are in charge of quality reporting for the practice) at the practice, redesigning clinical care processes, and investing in health information technology.  The enhancements to their electronic health records and patient registries allow practices to more easily identify gaps in care, alert physicians to these gaps during patient visits, and provide interim feedback on performance. 


In addition to achieving benchmark performance for quality, several physician groups also experienced favorable financial performance under the demonstrations performance payment methodology.  For patients with diabetes or coronary artery disease, Medicare expenditures grew more slowly for beneficiaries assigned to the physician groups than for beneficiaries in the comparison group with the same conditions.


This lower expenditure growth for chronic conditions as well as complex patients treated in the ambulatory and hospital settings contributed to four physician groups sharing in savings for improving the overall efficiency of care they furnish their patients.   


The four physician groups Dartmouth-Hitchcock Clinic, The Everett Clinic, Marshfield Clinic, and the University of Michigan Faculty Group Practice earned  $13.8 million in performance payments for improving the quality and cost efficiency of care as their share of a total of $17.4 million in Medicare savings.  This compares to two physician groups that earned $7.3 million in performance payments under the first year of the demonstration.


The results are for the second performance year of the demonstration which covered April 1, 2006 through March 31, 2007.  The initial three-year demonstration was extended for a fourth performance year, which runs through March 2009.


More information about the PGP demonstration may be found at:  To learn more about the PQRI please visit



For Immediate Release: Thursday, October 30, 2008
Contact: CMS Office of Public Affairs


The Centers for Medicare & Medicaid Services (CMS) today announced a new initiative for physicians to trade in their prescription pads and improve efficiency and safety when ordering drugs for patients with Medicare.  The initiative is included in the Medicare Physician Fee Schedule (MPFS) final rule for calendar year 2009. 


Widespread adoption of electronic prescribing can eliminate medication errors that result from the misreading of handwritten prescriptions. Medicare beneficiaries may also have reduced out-of-pocket costs as e-prescribing facilitates communication between prescribers and pharmacies on lower-cost generic alternatives.


Physicians and other eligible professionals who adopt and use qualified electronic prescribing (e-prescribing) systems to transmit prescriptions to pharmacies may earn an incentive payment of 2.0 percent of their total Medicare allowed charges during 2009.  This incentive is in addition to a 2.0 percent incentive payment for 2009 for physicians who successfully report measures under the Physician Quality Reporting Initiative (PQRI), and both incentive payments are in addition to the 1.1 percent fee schedule update required by the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA).  Thus, a physician who successfully reports under both the e-prescribing and PQRI initiatives could receive up to a 5.1 percent pay boost for 2009.


E-prescribing can greatly reduce the number of medication errors that jeopardize the health and safety of Medicare patients and waste precious health care dollars treating conditions that never should have happened, said CMS acting administrator Kerry Weems.  The Institute of Medicine says more than 1.5 million Americans are injured every year by drug errors.  E-prescribing lets providers knowup fronttheir patients medication history and the risk of dangerous interactions.


 To participate in the e-prescribing incentive program, physicians will need to have a qualified e-prescribing system with certain required capabilities.  Qualified systems must be able to: 


  • Communicate with the patients pharmacy;
  • Help the physician identify appropriate drugs and provide information on lower cost alternatives for the patient;
  • Provide information on formulary and tiered formulary medications; and
  • Generate alerts about possible adverse events, such as improper dosing, drug-to-drug interactions, or allergy concerns.

      To earn the incentive payment, physicians must successfully report one of three codes for the e-prescribing measure when submitting claims for specified types of medical visits, indicating either that:


  • They did not prescribe any medications during the visit;
  • They used e-prescribing for any medications prescribed during the visit; or
  • They did not use e-prescribing for a prescription because the law prohibits electronic prescribing for the specific type of drug, such as a controlled substance.

As part of its e-prescribing incentive program, Medicare will be providing information and other educational resources to physicians and their offices about available e-prescribing systems.


The e-prescribing incentive program is one of several provisions intended to promote access to higher quality and more efficient health care that is included in a final regulation updating the MPFS, which establishes payment rates for more than 7,000 types of services based on the resources required to furnish them.  The rates and policies adopted in the final rule will apply to services furnished on or after January 1, 2009.


Approximately 980,000 physicians and nonphysician practitioners (NPPs) bill Medicare under the MPFS for the services they furnish to beneficiaries.  Of these, nearly 95 percent accept Medicares fee schedule rate as payment in full for their services.  Medicare pays 80 percent of the fee schedule rate, while the beneficiary is responsible for the remaining 20 percent.


As required by MIPPA, which became law on July 15, 2008, payment rates for physician fee schedule services will be increased by 1.1 percent in 2009, rather than being reduced by 5.4 percent as would have happened if CMS had applied the physician fee schedule conversion factor projected in the proposed rule.  Total Medicare spending under the 2009 Physician Fee Schedule is projected at $61.9 billion, up 4 percent from the $59.5 billion projected for 2008. 


In the final rule, CMS also adopts improvements to the Physician Quality Reporting Initiative (PQRI), which allows eligible professionals to report quality measures relating to their clinical practice.  Physicians who successfully report on their cases during 2009 will be able to earn an incentive payment, in addition to the e-prescribing incentive payment of 2.0 percent of their total Medicare allowed charges.


Launched in 2007, the PQRI was expanded in July 2008 to provide alternative, streamlined methods for reporting.  Among the changes for 2009 is removal of the quality measure 125 that was used to report on the use of e-prescribing, since that is now the focus of the e-prescribing incentive program.  The final rule also adds 52 new quality measures (bringing the total number of measures to 153 from which eligible professionals can select from for 2009 PQRI), addressing such areas as osteoarthritis, rheumatoid arthritis, back pain, coronary artery bypass graft (CABG), chronic kidney disease (CKD), melanoma, oncology, coronary artery disease, hepatitis, and HIV/AIDS.  Eighteen of the new measures are reported exclusively through registries.


Finally, in the interest of patient care and safety, and to encourage prescribers and dispensers to adopt e-prescribing, CMS is reversing the modifications to the computer generated facsimile exemption in the CY 2008 MPFS final rule with comment period and reinstating the original computer-generated facsimile exemption that was adopted in the November 7, 2005 e-prescribing final rule, effective January 1, 2009. 


            The revised policies and payment rates will become effective January 1, 2009.


The final rule with comment will appear in the November 19 Federal Register. Comments on designated provisions are due by 5:00 p.m. Eastern time on December 29, and a final rule responding to the comments will be published at a later date.


             For more details on the general provisions of the rule, as well as CMSs implementation of the PQRI and e-Prescribing initiative, and MIPPA changes, see the Medicare Fact Sheets posted at:




            The text of the final MPFS rule can be downloaded from the CMS Web site at:







For Immediate Release: Monday, April 14, 2008
Contact: CMS Office of Public Affairs





On April 14, 2008, the Centers for Medicare & Medicaid Services (CMS) announced a proposed rule that would update payment policies and rates under the hospital inpatient prospective payment system (IPPS) for fiscal year (FY) 2009, beginning for discharges on or after October 1, 2008.  CMS is proposing to select nine categories of hospital-acquired conditions (HACs) for FY 2009 in addition to the eight selected one year ago. 


In addition to proposing expansion of the HAC list, CMS is proposing 43 new measures for the hospital quality measure reporting program.  More information about the proposed quality measures can be found at:




Section 5001(c) of the Deficit Reduction Act (DRA) of 2005 required the Secretary of the Department of Health and Human Services to select at least two conditions that are: (1) high cost, high volume, or both; (2) identified through ICD-9-CM coding as a complicating condition (CC) or major complicating condition (MCC) that, when present as a secondary diagnosis at discharge, results in payment at a higher MS-DRG; and (3) reasonably preventable through application of evidence-based guidelines.  The law further required hospitals to begin reporting on claims for discharges, beginning October 1, 2007, whether the selected conditions were present on admission (POA). 


Last year, CMS selected eight conditions for the HAC provision (See Table 1).  Beginning October 1, 2008, Medicare will no longer pay at a higher weighted MS-DRG for these conditions or any of the additional nine categories conditions we are proposing to add in this years rule.





CMS experts worked with public health and infectious disease professionals from the Centers for Disease Control and Prevention (CDC) to: 

  1. identify candidate preventable HACs and
  2. develop the process for hospitals to submit a POA indicator for each diagnosis listed on IPPS hospital Medicare claims. 


On December 17, 2007, CMS and CDC hosted a jointly-sponsored HAC and POA Listening Session to receive input from hospital associations and other interested individuals.  CMS and CDC received informal comments during the listening session and subsequently received numerous written comments.  The agenda, presentations, audio file, and written transcript of the Listening Session are available at:


CMS is also working with the Agency for Healthcare Research and Quality (AHRQ) and the National Quality Forum (NQF) to identify which of the 28 serious preventable errors (often called Never Events) identified by the NQF should be subject to the HACs provisions.  A separate fact sheet comparing the NQF list with the existing and proposed HACs is also being released today.




CMS is proposing to add an additional nine categories of conditions that when acquired in the hospital will no longer lead to higher Medicare payment.  CMS proposing to select:  surgical site infections for certain elective procedures, hypoglycemic coma, collapsed lung due to medical care, ventilator-associated pneumonia among other conditions.  In addition, CMS is proposing to create new codes to better identify two conditions that were previously selected:   foreign object retained after surgery; and pressure ulcers. 


In addition to the proposed changes above, CMS and CDC have worked with other stakeholders to identify additional conditions that might be candidates that might appropriately be subject to the HAC payment provision (See Table 2).  CMS is seeking comment on the extent to which each of these candidate conditions meets the statutory criteria for selection.


Comments on the proposed rule will be accepted through June 13.  CMS will respond to comments in a final rule to be issued on or before August 1, 2008.






Selected HAC

Medicare Data[1]

(FY 2007)


(ICD-9-CM Codes)

Selected Evidence-Based Guidelines


Foreign Object Retained After Surgery

  750 cases[2]

  $63,631/hospital stay[3]

998.4 (CC)

998.7 (CC)

NQF Serious Reportable Adverse Event


NQFs Safe Practices for Better Healthcare available at:

Air Embolism


  57 cases

  $71,636/hospital stay

999.1 (MCC)

NQF Serious Reportable Adverse Event


NQFs Safe Practices for Better Healthcare available at:

Blood Incompatibility


  24 cases

  $50,455/hospital stay

999.6 (CC)

NQF Serious Reportable Adverse Event


NQFs Safe Practices for Better Healthcare available at:






Stage III & IV Pressure Ulcers


  257,412 cases[4]

  $43,180/hospital stay

New codes

 (to replace


707.23 (MCC)

707.24 (MCC)

All other pressure ulcer codes will not be a CC.

NQF Serious Reportable Adverse Event


Available at:

Falls and Trauma:

  - Fractures

  - Dislocations

  - Intracranial Injuries

  - Crushing Injuries

  - Burns

  - Electric Shock


  193,566 cases[5]

  $33,894/hospital stay

Codes within these ranges on the

CC/MCC list:







NQF Serious Reportable Adverse Events address falls, electric shock, and burns


NQFs Safe Practices for Better Healthcare available at:

Catheter-Associated Urinary Tract Infection (UTI)

  12,185 cases

  $44,043/hospital stay

996.64 (CC)


Also excludes the following from acting as a CC/MCC:

112.2 (CC)

590.10 (CC)

590.11 (MCC)

590.2 (MCC)

590.3 (CC)

590.80 (CC)

590.81 (CC)

595.0 (CC)

597.0 (CC)

599.0 (CC)

Available at:





Vascular Catheter-Associated Infection

  29,536 cases

  $103,027/hospital stay 

999.31 (CC)

Available at:

Surgical Site Infection-Mediastinitis after Coronary Artery Bypass Graft (CABG)

  69 cases

  $299,237/hospital stay

519.2 (MCC)

And one of the following procedure codes:


Available at:







HAC Candidate

Medicare Data

(FY 2007)


(ICD-9-CM Codes)

Selected Evidence-Based Guidelines


Surgical Site Infections Following Elective Procedures:

  - Total Knee Replacement

  - Laparoscopic Gastric Bypass and Gastroenterostomy

  - Ligation and Stripping of Varicose Veins

Total Knee Replacement:  

  • 539 cases
  • $63,135/hospital stay

Laparoscopic Gastric Bypass and Gastroenterostomy:   

  • 208 cases
  • $180,142/hospital stay

Ligation and Stripping of Varicose Veins: 

  • 3 cases
  • $66,355/hospital stay

Total Knee Replacement (81.54):   996.66 (CC)

 and 998.59 (CC)


Laparoscopic Gastric Bypass (44.38)

and Gastroenterostomy (44.39):  998.59 (CC)


Varicose Veins

(38.59):  998.59 (CC)


Available at:


Available at:


Legionnaires Disease

        351 cases

        $86,014/hospital stay

482.84 (MCC)

Available at:


Available at:





Glycemic Control:

  - Diabetic Ketoacidosis

  - Nonketotic Hyperosmolar Coma

  - Diabetic Coma

  - Hypoglycemic Coma

Diabetic Ketoacidosis

  • 11,469 cases
  • $42,974/hospital stay

Nonketotic Hyperosmolar Coma

  • 3,248 cases
  • $35,215/hospital stay

Diabetic Coma

  • 1,131 cases
  • $45,989/hospital stay

Hypoglycemic Coma

  • 212 cases
  • $36,581/hospital stay

Diabetic Ketoacidosis:

 250.10 C 250.13 (CC)


Nonketotic Hyperosmolar Coma:

  250.20 C 250.23 (CC)


Diabetic Coma:  250.30 C 250.33 (CC)


Hypoglycemic Coma:

  251.0 (CC)

NQF Serious Reportable Adverse Events address hypoglycemia


Available at: 

Iatrogenic Pneumothorax

  • 22,665 cases
  • $75,089/hospital stay

512.1 (CC)

Available at:


  • 480 cases
  • $23,290/hospital stay

293.1 (CC)

Available at:




Ventilator-Associated Pneumonia (VAP)

  30,867 cases[6]

$135,795/hospital stay


The new code for VAP is 997.31.


To identify cases in current Medicare data, use a ventilator code (96.70 C 96.72), plus one of the following:

073.0 (MCC)

112.4 (MCC)

136.3 (MCC)

480.0-480.4 (MCCs)

480.8-480.9 (MCCs)

481 (MCC)

482.0-482.2 (MCC)

482.39-482.41 (MCCs)

482.49 (MCC)

482.81-482.84 (MCCs)

482.89 (MCC)

482.9 (MCC)

483.0 (MCC)

Available at:


Deep Vein Thrombosis (DVT)/Pulmonary Embolism (PE)

  • 140,010 cases
  • $50,937/hospital stay

453.40 C 453.42



Available at:


Available at:




Staphylococcus aureus Septicemia

  27,737 cases

  $84,976/hospital stay

038.11 (MCC)

995.91 (MCC)

995.92 (MCC)

998.59 (CC)

999.3 (CC)

Available at:


Available at: (Intravascular catheter-associated Staphylococcus aureus septicemia only)

Clostridium difficile-Associated Disease (CDAD)

  96,336 cases

  $59,153/hospital stay

008.45 (CC)

Available at:


Available at:



# # #

[1] For the IPPS FY 2009 proposed rule, the DRG analysis is based on data from the September 2007 update of the FY 2007 MedPAR file, which contains hospital bills received through September 30, 2007 for discharges through September 30, 2007.

[2] A case represents a patient discharge identified from the MedPAR database that met the associated HAC diagnosis/procedure criteria (a secondary diagnosis on the HAC list and, where appropriate, a procedure code described in conjunction with a specific HAC).

[3] Standardized charge is the total charge for a patient discharge record based on the CMS standardization file.  The average standardized charge for the HAC is the average charge for all patient discharge records that met the associated HAC criteria.


[4] The number of cases of pressure ulcers reflects CC/MCC assignments for codes 707.00-707.07, 707.09, which are currently being reported.  New proposed MCC codes 707.23-707.24 will be implemented on October 1, 2008. 

[5] Note:  The number of cases for the falls and trauma HAC is significantly higher for IPPS FY 2009 proposed rule than for IPPS FY 2008 final rule.  The IPPS FY 2008 final rule included cases in which patients fell out of bed only.  The  IPPS FY 2009 proposed rule includes all cases within the CC/MCC code range listed above.

[6] Note:  The number of cases for VAP is significantly lower for the IPPS FY 2009 proposed rule than the IPPS FY 2008 final rule.  The IPPS FY 2008 final rule included all pneumonia cases.  The  IPPS FY 2009 proposed rule includes only cases with a diagnosis of VAP and where a ventilator code was also included.




  • CMS releases 2009 IPPS final rule