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Theimpactof
qualityandCMS
scoresoncost
November 11, 2016
2© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Today’sspeakers
James Case
Director
jcase@kpmg.com
410.949.8895
Catherine “Cari” O’Leary, RN, BSN
Managing Director
coleary@kpmg.com
914-420-3903
— Cari is a member of the KPMG Provider
Solutions and National Leader for Clinical
Documentation Integrity (CDI) Practice
— She works with clients to improve clinical
operational effectiveness, particularly in
the areas of provider clinical
documentation and quality
— Cari advises hospitals on clinical and
regulatory issues that often result in
improvements in appropriate revenue
capture and overall collaboration between
clinical departments
— James is a member of the KPMG Provider
Solutions practice
— He works with clients to understand the
payment impacts associated with CMS,
State, and commercial reimbursement
models
— James has developed financial and
demand impact models to understand the
impact of episode payment methodologies
on numerous acute providers
OverviewoftheCMS
starratingsand
qualityperformance
metrics
4© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
OverviewoftheCMSStarRatingMethodology
forProviders
Hospital Compare
Measure
Mortality
Safety of Care
Readmission
Patient Experience
Effectiveness of Care
Timeliness of Care
Efficient Use of
Imaging
Mortality
Group Score
Safety of Care
Group Score
Readmission
Group Score
Patient Experience
Group Score
Effectiveness of Care
Group Score
Timeliness
Group Score
Imaging
Group Score
Hospital
Summary Score 3
2
1
4
5
Measure 1
Measure 2
Measure 61
Measure 62
Step 1: Select Measures Step 2: Group Measures
Step 3: Calculate
Group Score
Step 4: Generate
Summary Score
Step 5: Calculating
Star Ratings
Source: CMS.
5© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Step1:SelectingandStandardizingMeasures
Quality measure results include
many different types of scoring
information (e.g. times,
percentages, rates) and
therefore need to be:
Standardized – By calculating a z-score
for each measure the measures become
comparable
— The difference between an individual
hospital’s score and the overall mean
score for all hospitals divided by the
standard deviation for all hospitals
Adjusted for Outliers (Winsorization) –
Set all score to within 3 standard
deviations of the mean
Source: CMS.
6© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Step2:GroupMeasures(asofJuly2016)
Mortality Measures
(7 measures)
Safety of Care
Measures
(8 measures)
Effectiveness of Care
Measures
(18 measures)
Readmission
Measures
(8 measures)
Patient Experience
Measures
(11 measures)
Timeliness of Care
(7 measures)
Efficient Use of
Medical Imaging
Measures
(5 measures)
These seven groups of measures are closely aligned with the Value-based Purchasing Program
and the categories included on Hospital Compare.
By grouping measures into these categories, it will allow specific measures within the groups to
be added or removed from the star ratings in the future.
Source: CMS.
7© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Step3:CalculateGroupScores
CMS uses an analytical concept called Latent
Variable Models to calculate each group score.
The reasons that these models are used are
because:
— Quality of care is a hard to define variable to
predict
— Each hospital may report different amount of
cases in each measure
— Measures with larger amounts of cases are
more likely to predict overall quality of care
Examples of latent variables from the field of economics
include:
— quality of life
— business confidence
— morale
— happiness and conservatism
These are all variables which cannot be measured directly.
But linking these latent variables to other, observable
variables, the values of the latent variables can be inferred
from measurements of the observable variables.
Quality of life is a latent variable which cannot be
measured directly so observable variables are used to
infer quality of life.
Observable variables to measure quality of life include:
— wealth
— employment
— environment
— physical and mental health
— education
— recreation and leisure time
— social belonging
Source: CMS.
8© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Step4:GenerateSummaryScore
Mortality
Group Score
Safety of Care
Group Score
Readmission
Group Score
Patient Experience
Group Score
Effectiveness of Care
Group Score
Timeliness of Care
Group Score
Use of Imaging
Group Score
22% Weight
22% Weight
22% Weight
22% Weight
4% Weight
4% Weight
4% Weight
Weighted Average:
Hospital Summary Score
The following criteria were used to
determine weighting
— Measure importance
— Consistency
— Policy Priorities
— Stakeholder input
Source: CMS.
9© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Step5:AssigningaStarRating
CMS uses a statistical concept call k-Means clustering to translate each hospital’s
weighted score into an overall star rating.
— Two random data points are selected and the distance between those points and all other
points is calculated to see which one it is closer to (in the case of the star ratings they select 5
points)
— the average distance from those points to all other points in the group is calculated and
becomes the new central point
— This process is iterated until the central points are determined to be the minimum distance
between the central point and all points within that group
Small
Medium Large
Source: CMS.
10© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Step5:AssigningaStarRating
Rating Number of Hospitals Percentage of
Hospitals
Summary Score
Range in Cluster
100 2.73% (0.85, 2.06)
918 25.10% (0.23, 0.85)
1,777 48.58% (-0.35, 0.23)
728 19.90% (-1.00, -0.35)
135 3.69% (-1.97, -1.01)
Source: CMS.
Impactingcost
frommultiple
perspectives
12© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
It’simportanttothestarratingsfrommultiple
perspectives
Provider Costs to Consider
— Penalties and Rewards
— Lost Volume from Marketing
/ Branding
— Program Operating Costs
Consumer Costs to Consider
— Deductibles and Co-insurance
on Inpatient Hospitalizations
Government Costs to
Consider
— Reductions in utilization
— Steerage to low cost
providers
13© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Thestarratingsarealignedwithincentive
paymentstiedtotheunderlyingmeasures
Comparison of Inpatient Payments for Different
Star Levels
Average HAC %
(Penalty) /
Reward
Average VBP %
(Penalty) / Reward
Average
Readmission %
(Penalty) / Reward
Total Average %
(Penalty) / Reward
Star Rating
(0.5)% (0.5)% (0.8)% (1.8)%
(0.3)% (0.2)% (0.7)% (1.2)%
(0.2)% 0.2% (0.5)% (0.5)%
(0.2)% 0.5% (0.4)% (0.1)%
(0.1)% 1.0% (0.2)% 0.7%
14© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Consumerismwilldrivethelargestimpact
US News &
World Reports
LeapFrogThe Joint
Commission
Annual ranking of
hospitals published
to consumers
■ Reputational
Scoring
■ Data-driven Scoring
– Patient Survival
– Care Related
Indicators
– Process of care
– Patient Safety
Source of Data:
■ MedPar
■ AHA Survey
■ USNW Survey
Hospital Safety
Score published
annually to
consumers
■ Maternity Care
■ High Risk
Surgeries
■ In-hospital
complications
■ Resource Use
Source of Data:
■ Leapfrog Survey
■ AHRQ Patient
Safety Indicators
■ CMS data
■ AHA Survey
Multiple mandated
regulatory reporting
that include Hospital
Compare, Value
Based Purchasing,
Hospital Acquired
Conditions,
Readmission
Reduction
■ Reportable patient
outcome data
■ Reportable process
measures
■ Hospital operational
data
Source of Data:
■ Various government
required reporting
methods
Various types of
accreditations may be
obtain based on
resource and goals of
the healthcare setting
■ Standard driven
reporting on patient
outcomes, process
measures and
operational data
Source of Data
■ Healthcare
organization self
reports
■ TJC conducts site
visits on a routine
schedule
CMS Star
Ratings
Various
Specialty Area
or Clinical Area
Accreditations
Based on need or
healthcare setting
goals there are
multiple types of
accreditations such as
ACR, NSQIP
■ Guideline driven
reporting on
outcomes, process
measures and
operational data
Source of Data
■ Healthcare
organization self
reports
■ Agency conducts site
visits on a routine
schedule
15© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Higherstarratingswillhaveminimalimpact
onpatientout-of-pocketcostsInpatient Care Benefit Design for Traditional Medicare Patients
Part A Most people don't pay a monthly premium for Part A (sometimes called
"premium-free Part A").
Deductible and Coinsurance for Inpatient Services
$1,288 deductible for each benefit period (admission)
— Days 1-60: $0 coinsurance for each benefit period
— Days 61-90: $322 coinsurance per day of each benefit period
— Days 91 and beyond: $644 coinsurance per each "lifetime reserve day" after
day 90 for each benefit period (up to 60 days over your lifetime)
— Beyond lifetime reserve days: all costs
Part B Most people pay $104.90 each month.
Part B deductible and coinsurance $166 per year.
— After your deductible is met, you typically pay 20% of the Medicare-approved
amount for most doctor services (including most doctor services while you're a
hospital inpatient), outpatient therapy, and durable medical equipment.
16© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Hospitalswithhigherratingswillattractmore
andbetterpayingpatients,givingtheman
advantagewithepisodicpaymentmodels
Share of
Market
Total Market
Service Not
Offered
Patients Not
Served
Patients Competed for
and Lost
Patients
Competed for
and Won
Source: Kenichi Ohmae, The Mind of the Strategist – Business Planning for Competitive Advantage.
Gaps represent opportunities for
growth at a discharge and
episode level
17© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Narrowfocuswillleadtolimitedimpact
Guided by a narrow concept of readmission risk or by a primary motivation to avoid diagnosis-specific readmission penalties,
many hospitals have hired a new clinician to intensify transitional care services for a subgroup of patients. This strategy may
greatly improve care for the individuals served but may not result in the desired outcome at the organizational level.
— Hospital A hires a transitional care full-time equivalent (FTE) to provide enhanced services to heart failure patients transitioning to
home without home care.
— This FTE attempts to manually screen for heart failure patients, narrows to those with Medicare fee for service, and further arrows
to those who are being discharged to home without home care.
— The transitional care FTE screens three times more patients than he or she serves and suspects he or she misses several patients
identified late in the hospitalization as having heart failure.
— Ultimately, this FTE provides high-quality transitional care services to 200 patients and reduces readmissions in this subgroup by
20 percent.
Example of Impact using diagnosis-specific approach
Medicare Discharge per Year 5,000 discharges
Medicare Readmission Rate 20%
Medicare Readmissions per Year 1,000
Transitional care heart failure intervention per year 200 discharges
Heart Failure Readmission Rate 25%
Expected Readmissions 50 readmissions
Expected Impact of Intervention Reduce Readmission Rate to 20%
Readmissions Averted by Intervention 10 readmissions
Impact of Strategy on Medicare Readmissions 1.0%
Apotentialstrategyto
improvequalitywitha
returnoninvestment
19© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
IncreasedFocusonQualityReporting
To hospitals, increased attention on quality
reporting provides:
— Insights as to gaps for internal improvement
— Differentiation to customers
— Higher revenues for higher quality services
— A need for credible, relevant, complete and
accurate quality measures
Healthcare quality and efficiency measures are used by
federal and state regulatory agencies, as well as others, to
determine the effectiveness of an organization’s patient care
delivery.
Clear evidence of the reliability of quality measures is, and will be, increasingly important as
the focus on the financial impact of quality outcomes to healthcare organizations increases.
20© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
AssumptionsandOurViewpoints
Assumptions
— All hospitals focus on and report on “quality”, but the approaches, priorities, definitions, and reporting differ
across the country
— The hospital strategic goals are aligned to the quality reporting objectives
— High Cost does not equate to High Quality and vice versa
Viewpoint #2 – Clinical Data Integrity
Regardless of the measures chosen, the underlying data
may not support the reported “quality”, which can have
various implications for hospitals
Why does this matter?
— Assurance around appropriateness of reporting
— Enhanced compliance under increased regulatory
scrutiny
Viewpoint #1 – The Core Metrics
A core number of measurable outcomes are consistent
across the major quality reporting services and will drive a
large portion of real value in the future
Why does this matter?
— Improved patient outcomes
— Enhanced reputation and brand for clinical quality
— Improved reimbursement through CMS’ value-based
payment and other state-specific measures
— Opportunities for physician alignment through shared
savings and pay-for-outcome performance models
21© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Targetedconditions:AcuteMyocardial
Infarction(AMI)
CMS is linking cardiac episode or bundled payment model for acute myocardial infarction
(MS-DRG 280-282, 246-251) to quality measures
Acute Myocardial Infarction (AMI) (aka heart attack):
Commonly known as a heart attack, acute myocardial infarction (AMI)
occurs when the blood flow that brings oxygen to the heart muscle is
severely reduced or cut off completely. This happens because coronary
arteries that supply the heart muscle with blood flow can slowly become
narrowed from a buildup of fat, cholesterol and other substances that
together are called plaque.
Table 1: Quality reporting measures for AMI
Quality measure
Weight in composite
quality score
Quality domain/weight
MORT-30-AMI (NQF #0230) 50% Outcome / 80%
AMI Excess Days 20%
Hybrid AMI Mortality (NQF #2473) 10%
HCAHPS Survey (NQF #0166) 20% Patient Experience / 20%
22© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Targetedconditions:OverviewofAMI
— About 720,000 people in the U.S. suffer heart attacks each year, with an average cost per
episode of $24,200
— Complications in cardiac care can lead to increased risk of readmission, length of stay,
increases in cost and utilization of resources and mortality
— Risk factors for AMI:
— Age: The majority of people who die of coronary heart disease are 65 or older.
— Smoking
— High LDL cholesterol
— Diabetes
AMI Median
Length of Stay (LOS) 4.6 days
30-day Readmission Rate 19.9%
Inpatient Cost $24,200
Source: AHRQ,HCUP, Statistical Brief # 172: Conditions With the Largest Number of Adult Hospital Readmissions by Payer, 2011
23© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
VisualizationAcrosstheContinuum
O2
Patient Care Managed at Home
CAD, HTN, diabetes,
smoking, obesity
Adverse Event
Chest Pain
Patient Accesses
Emergency Department
Emergency Department
Cath Lab Procedure
Acute Care Delivery
Surgical Procedure
Surgical prep and procedures
On/Off pump, Robotics
PACU/ICU Recovery
Ventilator, Chest Tubes, Pacer
Discharge to Home/SNF/LTAC Additional Community Resources
Delays to Care:
• Initial assessment/tx plan
• Thrombolytics, Cath Lab
• EKG, Echocardiogram
• Admission procedures
• Cardiac, pulmonary and
cardiac surgery consults
• Cardiac medication adj
• Other medical treatments for
CAD, HTN, diabetes
Complications:
• Bleeding, infections
• Pneumonia, blood clots
• A-Fib, fluid management
24© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
AcuteMI–DocumentationandCoding
PosSigns, symptoms, and diagnostic
criteria for evidence of a possible
AMI:
— Chest pain (angina), SOB,
“squeezing sensation”, n/v, cough,
dizziness, “impending doom”,
anxiety, sweating (may be profuse),
may have no chest discomfort
— Troponin or Cardiac Enzymes
— EKG changes
Visible MI within last 4 weeks
Diagnostic Evidence
— Diagnostic Anti-thrombotic treatment
— Telemetry monitoring
— Heparin / ASA in combination with
platelet inhibitor
— Nitrates (Nitroglycerin)
— Beta-Blockers
— Oxygen
— MSO4
— ACE-inhibitors or ARBs
Evidence
Treatment and Monitoring
Non-ST elevation, Non Q-wave, ST elevation MI, Other specified, Unspecified
– all terms related to “type” = acute MI
25© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
CaseStudy:Discussion
Potential Root Cause
Issues in quality reporting of AMI
Clinical documentation supportive of physician treating a possible / probably AMI (as noted by
coding rules for “within 4 weeks”) and coded /billed to AMI
— Insufficient communication with physicians, nurses, coding teams
— QI definitions and clinical guidelines without collaboration with CDI
— Diminished importance of clinical documentation process in clinical governance
— Potential for mixed messages to patient on actual diagnoses
— Siloes between existing CDI team and QI resulting in lack of coordinated effort around
most impactful measures
Lack of integration of among the clinical, surveillance, and documentation/ coding definitions and
reporting requirements
Potential loss of revenue vs. penalty for QI measures
Lack of collaboration and knowledge sharing amongst the various teams (e.g. QA/PI, coding,
CDI, physicians, infection prevention and control, Marketing)
26© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Technology
MappingRootCause
Regulatory Compliance
Human Capital Management
Pre-Arrival Arrival
Delivery of Care, Service
Integrity and Documentation
Post Care and Financial
Services
Triage
(RN &
Disease
Mgmt.)
Pre-
registration
Service
Authorizati
on
Scheduli
ng/ABN
Insuranc
e/
Eligibility
Verificati
on
Financial
Counselin
g
Service
Authorizat
ion
(unsched
uled
visits)
Validate
insurance
& record
demograp
hic
informatio
n
Completio
n of forms
Co-pay
Collecti
on
Check-in
to
appropria
te dept.
Financia
l
Counseli
ng
Insurance/
Eligibility
Verification
(unschedul
ed visits)
Revenu
e
Capture
Service/
HIM/
Documen
-tation
Chart
Review
Charge
Capture/
Coding
Care
Quality
Coordinati
on (CQC
Pricing
Transparen
cy
Bad
Debt
Mgmt
.
Billin
g
Collectio
ns
Patient
Paymen
t
Collecti
on
Denia
l
Mgmt
.
Charity
Care
Outsour
ce
Mgmt.
Contract
Mgmt.
Cash
Postin
g
Post-
Servi
ce
Pre-
Servi
ce
Information
Culture
27© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Opportunitiesforclinicalimprovement:
Establishastandardofcare
The standard of care embodies the evidence-based pathway, and requires a process of
definition, consensus and approval, and monitoring
Define Obtain Consensus Monitor and Follow-up
Define a pathway
based upon target
LOS, timing of
interventions and
medical milestones
which target clinical
outcomes; order
sets and protocols
flow from the
pathway
Demonstrate
formal
commitment
via approval
from
governing
bodies of the
medical staff,
nursing staff,
and hospital
senior
leadership
Establish
accountability
metrics and
processes,
and
concurrent
processes of
care versus
retrospective
processes
Maintain
formal
reporting of
outcome and
accountability
metrics to
ensure
compliance
Unwarranted
variations
should be
concurrently
managed
through an
escalation
process
Pathway and
medical
milestones
must be
concurrently
used to
manage both
delivery of
care, and
progression
of care
28© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Emphasizingstandardsofcare:Leading
practicesforAMI
Diagnosis and
Assessment
1
Treatment
Pre-stabilization
2
Treatment
Post-stabilization
3
Post-discharge
Rehabilitation &
Follow-up Care
4
Diagnosis and Assessment: Perform a clinical examination, physical and necessary tests and screenings. Collect appropriate
blood work including measurements of serum natriuretic peptides and echocardiography within 48 hours of admission
Treatment Post-stabilization: Determine if beta-blocker treatment is necessary based on vital signs and symptoms or offer
angiotensin-converting enzyme inhibitor. Closely monitor the person’s renal function, electrolytes, heart rate, blood pressure
and overall clinical status during treatment and ensure that the person’s condition is stable for typically 48 hours after starting or
restarting beta-blockers and before discharging from hospital.
Treatment Pre-stabilization: Determine whether patient needs pharmacological or non-pharmacological treatment. Closely
monitor the person’s renal function, weight and urine output during diuretic therapy. Discuss with the person the best strategies
of coping with an increased urine output
Post Discharge and Rehab: Schedule follow-up clinical assessment with a member of the specialist heart failure team within 2
weeks of the person being discharged from hospital. Continue ongoing care management in primary care, including ongoing
monitoring and care provided by the multidisciplinary team and communicate information about the patient’s condition,
treatment and prognosis
Source: Modified from IHI Clinical Pathway; IHI and other existing materials
29© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International
Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
Organizationalself-assessment
High maturity organizations have a ‘population health’ focus, which means they look
beyond their ‘four walls’; these organizations typically consider the following:
What is our organizations understanding of the quality metrics that drive payment?
What are our current gaps and processes within our organization that are hindering good outcomes?
What are our clinical pathways, order sets, protocols, and metrics that guide patient care through the
acute and post acute episodes of care?
How do we use patient data from the EMR to facilitate the care of the patient?
What is our current care management structure, and how does it focus on coordinating transitions of
care, driving quality, and reducing readmissions through all patient care settings?
How does the Interdisciplinary Care Coordination process use medical milestones to foster efficient
movement and transitions through the appropriate sites of service back to home and the community?
How does Clinical Variation Management drive increased quality and safety, improve clinical outcomes,
and ensure medically appropriate care and resource utilization?
Q&A
Thank You
© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of
independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss
entity.
All rights reserved.
The KPMG name and logo are registered trademarks or trademarks of KPMG International.
The information contained herein is of a general nature and is not intended to address the circumstances of
any particular individual or entity. Although we endeavor to provide accurate and timely information, there can
be no guarantee that such information is accurate as of the date it is received or that it will continue to be
accurate in the future. No one should act on such information without appropriate professional advice after a
thorough examination of the particular situation.
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The impact of quality and CMS scores on cost

  • 2. 2© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Today’sspeakers James Case Director jcase@kpmg.com 410.949.8895 Catherine “Cari” O’Leary, RN, BSN Managing Director coleary@kpmg.com 914-420-3903 — Cari is a member of the KPMG Provider Solutions and National Leader for Clinical Documentation Integrity (CDI) Practice — She works with clients to improve clinical operational effectiveness, particularly in the areas of provider clinical documentation and quality — Cari advises hospitals on clinical and regulatory issues that often result in improvements in appropriate revenue capture and overall collaboration between clinical departments — James is a member of the KPMG Provider Solutions practice — He works with clients to understand the payment impacts associated with CMS, State, and commercial reimbursement models — James has developed financial and demand impact models to understand the impact of episode payment methodologies on numerous acute providers
  • 4. 4© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. OverviewoftheCMSStarRatingMethodology forProviders Hospital Compare Measure Mortality Safety of Care Readmission Patient Experience Effectiveness of Care Timeliness of Care Efficient Use of Imaging Mortality Group Score Safety of Care Group Score Readmission Group Score Patient Experience Group Score Effectiveness of Care Group Score Timeliness Group Score Imaging Group Score Hospital Summary Score 3 2 1 4 5 Measure 1 Measure 2 Measure 61 Measure 62 Step 1: Select Measures Step 2: Group Measures Step 3: Calculate Group Score Step 4: Generate Summary Score Step 5: Calculating Star Ratings Source: CMS.
  • 5. 5© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Step1:SelectingandStandardizingMeasures Quality measure results include many different types of scoring information (e.g. times, percentages, rates) and therefore need to be: Standardized – By calculating a z-score for each measure the measures become comparable — The difference between an individual hospital’s score and the overall mean score for all hospitals divided by the standard deviation for all hospitals Adjusted for Outliers (Winsorization) – Set all score to within 3 standard deviations of the mean Source: CMS.
  • 6. 6© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Step2:GroupMeasures(asofJuly2016) Mortality Measures (7 measures) Safety of Care Measures (8 measures) Effectiveness of Care Measures (18 measures) Readmission Measures (8 measures) Patient Experience Measures (11 measures) Timeliness of Care (7 measures) Efficient Use of Medical Imaging Measures (5 measures) These seven groups of measures are closely aligned with the Value-based Purchasing Program and the categories included on Hospital Compare. By grouping measures into these categories, it will allow specific measures within the groups to be added or removed from the star ratings in the future. Source: CMS.
  • 7. 7© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Step3:CalculateGroupScores CMS uses an analytical concept called Latent Variable Models to calculate each group score. The reasons that these models are used are because: — Quality of care is a hard to define variable to predict — Each hospital may report different amount of cases in each measure — Measures with larger amounts of cases are more likely to predict overall quality of care Examples of latent variables from the field of economics include: — quality of life — business confidence — morale — happiness and conservatism These are all variables which cannot be measured directly. But linking these latent variables to other, observable variables, the values of the latent variables can be inferred from measurements of the observable variables. Quality of life is a latent variable which cannot be measured directly so observable variables are used to infer quality of life. Observable variables to measure quality of life include: — wealth — employment — environment — physical and mental health — education — recreation and leisure time — social belonging Source: CMS.
  • 8. 8© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Step4:GenerateSummaryScore Mortality Group Score Safety of Care Group Score Readmission Group Score Patient Experience Group Score Effectiveness of Care Group Score Timeliness of Care Group Score Use of Imaging Group Score 22% Weight 22% Weight 22% Weight 22% Weight 4% Weight 4% Weight 4% Weight Weighted Average: Hospital Summary Score The following criteria were used to determine weighting — Measure importance — Consistency — Policy Priorities — Stakeholder input Source: CMS.
  • 9. 9© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Step5:AssigningaStarRating CMS uses a statistical concept call k-Means clustering to translate each hospital’s weighted score into an overall star rating. — Two random data points are selected and the distance between those points and all other points is calculated to see which one it is closer to (in the case of the star ratings they select 5 points) — the average distance from those points to all other points in the group is calculated and becomes the new central point — This process is iterated until the central points are determined to be the minimum distance between the central point and all points within that group Small Medium Large Source: CMS.
  • 10. 10© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Step5:AssigningaStarRating Rating Number of Hospitals Percentage of Hospitals Summary Score Range in Cluster 100 2.73% (0.85, 2.06) 918 25.10% (0.23, 0.85) 1,777 48.58% (-0.35, 0.23) 728 19.90% (-1.00, -0.35) 135 3.69% (-1.97, -1.01) Source: CMS.
  • 12. 12© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. It’simportanttothestarratingsfrommultiple perspectives Provider Costs to Consider — Penalties and Rewards — Lost Volume from Marketing / Branding — Program Operating Costs Consumer Costs to Consider — Deductibles and Co-insurance on Inpatient Hospitalizations Government Costs to Consider — Reductions in utilization — Steerage to low cost providers
  • 13. 13© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Thestarratingsarealignedwithincentive paymentstiedtotheunderlyingmeasures Comparison of Inpatient Payments for Different Star Levels Average HAC % (Penalty) / Reward Average VBP % (Penalty) / Reward Average Readmission % (Penalty) / Reward Total Average % (Penalty) / Reward Star Rating (0.5)% (0.5)% (0.8)% (1.8)% (0.3)% (0.2)% (0.7)% (1.2)% (0.2)% 0.2% (0.5)% (0.5)% (0.2)% 0.5% (0.4)% (0.1)% (0.1)% 1.0% (0.2)% 0.7%
  • 14. 14© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Consumerismwilldrivethelargestimpact US News & World Reports LeapFrogThe Joint Commission Annual ranking of hospitals published to consumers ■ Reputational Scoring ■ Data-driven Scoring – Patient Survival – Care Related Indicators – Process of care – Patient Safety Source of Data: ■ MedPar ■ AHA Survey ■ USNW Survey Hospital Safety Score published annually to consumers ■ Maternity Care ■ High Risk Surgeries ■ In-hospital complications ■ Resource Use Source of Data: ■ Leapfrog Survey ■ AHRQ Patient Safety Indicators ■ CMS data ■ AHA Survey Multiple mandated regulatory reporting that include Hospital Compare, Value Based Purchasing, Hospital Acquired Conditions, Readmission Reduction ■ Reportable patient outcome data ■ Reportable process measures ■ Hospital operational data Source of Data: ■ Various government required reporting methods Various types of accreditations may be obtain based on resource and goals of the healthcare setting ■ Standard driven reporting on patient outcomes, process measures and operational data Source of Data ■ Healthcare organization self reports ■ TJC conducts site visits on a routine schedule CMS Star Ratings Various Specialty Area or Clinical Area Accreditations Based on need or healthcare setting goals there are multiple types of accreditations such as ACR, NSQIP ■ Guideline driven reporting on outcomes, process measures and operational data Source of Data ■ Healthcare organization self reports ■ Agency conducts site visits on a routine schedule
  • 15. 15© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Higherstarratingswillhaveminimalimpact onpatientout-of-pocketcostsInpatient Care Benefit Design for Traditional Medicare Patients Part A Most people don't pay a monthly premium for Part A (sometimes called "premium-free Part A"). Deductible and Coinsurance for Inpatient Services $1,288 deductible for each benefit period (admission) — Days 1-60: $0 coinsurance for each benefit period — Days 61-90: $322 coinsurance per day of each benefit period — Days 91 and beyond: $644 coinsurance per each "lifetime reserve day" after day 90 for each benefit period (up to 60 days over your lifetime) — Beyond lifetime reserve days: all costs Part B Most people pay $104.90 each month. Part B deductible and coinsurance $166 per year. — After your deductible is met, you typically pay 20% of the Medicare-approved amount for most doctor services (including most doctor services while you're a hospital inpatient), outpatient therapy, and durable medical equipment.
  • 16. 16© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Hospitalswithhigherratingswillattractmore andbetterpayingpatients,givingtheman advantagewithepisodicpaymentmodels Share of Market Total Market Service Not Offered Patients Not Served Patients Competed for and Lost Patients Competed for and Won Source: Kenichi Ohmae, The Mind of the Strategist – Business Planning for Competitive Advantage. Gaps represent opportunities for growth at a discharge and episode level
  • 17. 17© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Narrowfocuswillleadtolimitedimpact Guided by a narrow concept of readmission risk or by a primary motivation to avoid diagnosis-specific readmission penalties, many hospitals have hired a new clinician to intensify transitional care services for a subgroup of patients. This strategy may greatly improve care for the individuals served but may not result in the desired outcome at the organizational level. — Hospital A hires a transitional care full-time equivalent (FTE) to provide enhanced services to heart failure patients transitioning to home without home care. — This FTE attempts to manually screen for heart failure patients, narrows to those with Medicare fee for service, and further arrows to those who are being discharged to home without home care. — The transitional care FTE screens three times more patients than he or she serves and suspects he or she misses several patients identified late in the hospitalization as having heart failure. — Ultimately, this FTE provides high-quality transitional care services to 200 patients and reduces readmissions in this subgroup by 20 percent. Example of Impact using diagnosis-specific approach Medicare Discharge per Year 5,000 discharges Medicare Readmission Rate 20% Medicare Readmissions per Year 1,000 Transitional care heart failure intervention per year 200 discharges Heart Failure Readmission Rate 25% Expected Readmissions 50 readmissions Expected Impact of Intervention Reduce Readmission Rate to 20% Readmissions Averted by Intervention 10 readmissions Impact of Strategy on Medicare Readmissions 1.0%
  • 19. 19© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. IncreasedFocusonQualityReporting To hospitals, increased attention on quality reporting provides: — Insights as to gaps for internal improvement — Differentiation to customers — Higher revenues for higher quality services — A need for credible, relevant, complete and accurate quality measures Healthcare quality and efficiency measures are used by federal and state regulatory agencies, as well as others, to determine the effectiveness of an organization’s patient care delivery. Clear evidence of the reliability of quality measures is, and will be, increasingly important as the focus on the financial impact of quality outcomes to healthcare organizations increases.
  • 20. 20© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. AssumptionsandOurViewpoints Assumptions — All hospitals focus on and report on “quality”, but the approaches, priorities, definitions, and reporting differ across the country — The hospital strategic goals are aligned to the quality reporting objectives — High Cost does not equate to High Quality and vice versa Viewpoint #2 – Clinical Data Integrity Regardless of the measures chosen, the underlying data may not support the reported “quality”, which can have various implications for hospitals Why does this matter? — Assurance around appropriateness of reporting — Enhanced compliance under increased regulatory scrutiny Viewpoint #1 – The Core Metrics A core number of measurable outcomes are consistent across the major quality reporting services and will drive a large portion of real value in the future Why does this matter? — Improved patient outcomes — Enhanced reputation and brand for clinical quality — Improved reimbursement through CMS’ value-based payment and other state-specific measures — Opportunities for physician alignment through shared savings and pay-for-outcome performance models
  • 21. 21© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Targetedconditions:AcuteMyocardial Infarction(AMI) CMS is linking cardiac episode or bundled payment model for acute myocardial infarction (MS-DRG 280-282, 246-251) to quality measures Acute Myocardial Infarction (AMI) (aka heart attack): Commonly known as a heart attack, acute myocardial infarction (AMI) occurs when the blood flow that brings oxygen to the heart muscle is severely reduced or cut off completely. This happens because coronary arteries that supply the heart muscle with blood flow can slowly become narrowed from a buildup of fat, cholesterol and other substances that together are called plaque. Table 1: Quality reporting measures for AMI Quality measure Weight in composite quality score Quality domain/weight MORT-30-AMI (NQF #0230) 50% Outcome / 80% AMI Excess Days 20% Hybrid AMI Mortality (NQF #2473) 10% HCAHPS Survey (NQF #0166) 20% Patient Experience / 20%
  • 22. 22© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Targetedconditions:OverviewofAMI — About 720,000 people in the U.S. suffer heart attacks each year, with an average cost per episode of $24,200 — Complications in cardiac care can lead to increased risk of readmission, length of stay, increases in cost and utilization of resources and mortality — Risk factors for AMI: — Age: The majority of people who die of coronary heart disease are 65 or older. — Smoking — High LDL cholesterol — Diabetes AMI Median Length of Stay (LOS) 4.6 days 30-day Readmission Rate 19.9% Inpatient Cost $24,200 Source: AHRQ,HCUP, Statistical Brief # 172: Conditions With the Largest Number of Adult Hospital Readmissions by Payer, 2011
  • 23. 23© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. VisualizationAcrosstheContinuum O2 Patient Care Managed at Home CAD, HTN, diabetes, smoking, obesity Adverse Event Chest Pain Patient Accesses Emergency Department Emergency Department Cath Lab Procedure Acute Care Delivery Surgical Procedure Surgical prep and procedures On/Off pump, Robotics PACU/ICU Recovery Ventilator, Chest Tubes, Pacer Discharge to Home/SNF/LTAC Additional Community Resources Delays to Care: • Initial assessment/tx plan • Thrombolytics, Cath Lab • EKG, Echocardiogram • Admission procedures • Cardiac, pulmonary and cardiac surgery consults • Cardiac medication adj • Other medical treatments for CAD, HTN, diabetes Complications: • Bleeding, infections • Pneumonia, blood clots • A-Fib, fluid management
  • 24. 24© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. AcuteMI–DocumentationandCoding PosSigns, symptoms, and diagnostic criteria for evidence of a possible AMI: — Chest pain (angina), SOB, “squeezing sensation”, n/v, cough, dizziness, “impending doom”, anxiety, sweating (may be profuse), may have no chest discomfort — Troponin or Cardiac Enzymes — EKG changes Visible MI within last 4 weeks Diagnostic Evidence — Diagnostic Anti-thrombotic treatment — Telemetry monitoring — Heparin / ASA in combination with platelet inhibitor — Nitrates (Nitroglycerin) — Beta-Blockers — Oxygen — MSO4 — ACE-inhibitors or ARBs Evidence Treatment and Monitoring Non-ST elevation, Non Q-wave, ST elevation MI, Other specified, Unspecified – all terms related to “type” = acute MI
  • 25. 25© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. CaseStudy:Discussion Potential Root Cause Issues in quality reporting of AMI Clinical documentation supportive of physician treating a possible / probably AMI (as noted by coding rules for “within 4 weeks”) and coded /billed to AMI — Insufficient communication with physicians, nurses, coding teams — QI definitions and clinical guidelines without collaboration with CDI — Diminished importance of clinical documentation process in clinical governance — Potential for mixed messages to patient on actual diagnoses — Siloes between existing CDI team and QI resulting in lack of coordinated effort around most impactful measures Lack of integration of among the clinical, surveillance, and documentation/ coding definitions and reporting requirements Potential loss of revenue vs. penalty for QI measures Lack of collaboration and knowledge sharing amongst the various teams (e.g. QA/PI, coding, CDI, physicians, infection prevention and control, Marketing)
  • 26. 26© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Technology MappingRootCause Regulatory Compliance Human Capital Management Pre-Arrival Arrival Delivery of Care, Service Integrity and Documentation Post Care and Financial Services Triage (RN & Disease Mgmt.) Pre- registration Service Authorizati on Scheduli ng/ABN Insuranc e/ Eligibility Verificati on Financial Counselin g Service Authorizat ion (unsched uled visits) Validate insurance & record demograp hic informatio n Completio n of forms Co-pay Collecti on Check-in to appropria te dept. Financia l Counseli ng Insurance/ Eligibility Verification (unschedul ed visits) Revenu e Capture Service/ HIM/ Documen -tation Chart Review Charge Capture/ Coding Care Quality Coordinati on (CQC Pricing Transparen cy Bad Debt Mgmt . Billin g Collectio ns Patient Paymen t Collecti on Denia l Mgmt . Charity Care Outsour ce Mgmt. Contract Mgmt. Cash Postin g Post- Servi ce Pre- Servi ce Information Culture
  • 27. 27© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Opportunitiesforclinicalimprovement: Establishastandardofcare The standard of care embodies the evidence-based pathway, and requires a process of definition, consensus and approval, and monitoring Define Obtain Consensus Monitor and Follow-up Define a pathway based upon target LOS, timing of interventions and medical milestones which target clinical outcomes; order sets and protocols flow from the pathway Demonstrate formal commitment via approval from governing bodies of the medical staff, nursing staff, and hospital senior leadership Establish accountability metrics and processes, and concurrent processes of care versus retrospective processes Maintain formal reporting of outcome and accountability metrics to ensure compliance Unwarranted variations should be concurrently managed through an escalation process Pathway and medical milestones must be concurrently used to manage both delivery of care, and progression of care
  • 28. 28© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Emphasizingstandardsofcare:Leading practicesforAMI Diagnosis and Assessment 1 Treatment Pre-stabilization 2 Treatment Post-stabilization 3 Post-discharge Rehabilitation & Follow-up Care 4 Diagnosis and Assessment: Perform a clinical examination, physical and necessary tests and screenings. Collect appropriate blood work including measurements of serum natriuretic peptides and echocardiography within 48 hours of admission Treatment Post-stabilization: Determine if beta-blocker treatment is necessary based on vital signs and symptoms or offer angiotensin-converting enzyme inhibitor. Closely monitor the person’s renal function, electrolytes, heart rate, blood pressure and overall clinical status during treatment and ensure that the person’s condition is stable for typically 48 hours after starting or restarting beta-blockers and before discharging from hospital. Treatment Pre-stabilization: Determine whether patient needs pharmacological or non-pharmacological treatment. Closely monitor the person’s renal function, weight and urine output during diuretic therapy. Discuss with the person the best strategies of coping with an increased urine output Post Discharge and Rehab: Schedule follow-up clinical assessment with a member of the specialist heart failure team within 2 weeks of the person being discharged from hospital. Continue ongoing care management in primary care, including ongoing monitoring and care provided by the multidisciplinary team and communicate information about the patient’s condition, treatment and prognosis Source: Modified from IHI Clinical Pathway; IHI and other existing materials
  • 29. 29© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Organizationalself-assessment High maturity organizations have a ‘population health’ focus, which means they look beyond their ‘four walls’; these organizations typically consider the following: What is our organizations understanding of the quality metrics that drive payment? What are our current gaps and processes within our organization that are hindering good outcomes? What are our clinical pathways, order sets, protocols, and metrics that guide patient care through the acute and post acute episodes of care? How do we use patient data from the EMR to facilitate the care of the patient? What is our current care management structure, and how does it focus on coordinating transitions of care, driving quality, and reducing readmissions through all patient care settings? How does the Interdisciplinary Care Coordination process use medical milestones to foster efficient movement and transitions through the appropriate sites of service back to home and the community? How does Clinical Variation Management drive increased quality and safety, improve clinical outcomes, and ensure medically appropriate care and resource utilization?
  • 31. © 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name and logo are registered trademarks or trademarks of KPMG International. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. kpmg.com/socialmedia