The AAMC submitted a Dec.15 comment letter to the Health Resources and Services Administration (HRSA) in response to a request for comment on the proposed establishment of a quality bonus system within the Children’s Hospital GME Program (CHGME).
The CHGME Program supports GME in freestanding children’s hospitals – hospitals that serve predominately children operating under their own Medicare provider number – that train primary care pediatricians and pediatric medical and surgical subspecialties, as well as provide pediatric rotations for non-pediatric residents.
HRSA is proposing that the quality bonus system would evaluate children’s hospitals’ engagement in activities to improve access, quality, and cost effectiveness of health care in the pediatric community by both the children’s hospital and the resident. Hospitals that participate in the program and meet certain standards would be eligible for bonus payments.
Although the implementation of such a pay-for-performance program would be new, since the program’s third reauthorization in 2006, Congress has required CHGME recipients to provide annual reports including data related to the operation of training their programs, such as numbers of residents trained, types of training provided, and changes made in training to prepare residents for caring for children who are underserved and for improvement of quality and patient safety.
The AAMC’s letter notes that the quality bonus system should evaluate programs based on the training program’s goals, including measures specific to the quality of resident training, and not based on hospital quality measures that may be outside the scope of the program. The association does not believe it is appropriate, for the purposes of evaluating this very specific program focused on pediatric physician training, to measure hospitals on broad outcomes that are not exclusively tied to the goals of the CHGME program.
As HRSA develops criteria for the quality bonus system, the AAMC urges the agency to remember that the purpose of the CHGME grants is to pay for graduate medical education. While HRSA acknowledges that designing a GME quality improvement initiative is complex, the AAMC believes the quality bonus payments must be tied to the training program, not to other activities in which a hospital may engage, and should incentivize activities that support the program’s goals.
Furthermore, because the quality bonus program is a new program, the AAMC notes that it is important that the implementation be gradual so that participating hospitals have an opportunity to fully understand the criteria and reporting requirements. Lastly, the association encourages HRSA to allow for sufficient time to monitor the program before expanding criteria beyond fiscal year (FY) 2019 to ensure that the desired activities are being appropriately evaluated and rewarded and do not result in unintended consequences.