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Quality Measure Results for Episodes of Care that Span Multiple CCNs

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1 Quality Measure Results for Episodes of Care that Span Multiple CCNs
Change Review Process Meeting 9/17/2015 Lisa Nelson Lantana Consulting Group

2 Issue Overview Emergency Department process quality measures include timing logic that spans 2 kinds of encounters (ED Visits and Inpatient Encounters)occuring in a series. ED-1 & ED-2 focus on Inpatient Encounters where there was an ED Visit that concluded within an hour before or concurrent with the start of the IP Encounter. ED-3 focuses on ED Visits where no IP Encounter started within 6 hours after the ED Visit ended. Do the measure definitions work as expected when the two encounters occur at facilities from distinct CCNs? What is a hospital’s CCN? A hospital’s CMS’ Certification Number (CCN), is the hospital’s identification number and is linked to its Medicare provider agreement.  The CCN is used for CMS certification.  Certain types of health care facilities, including hospitals, seeking to participate in the Medicare program are required not only to satisfactorily complete the Medicare enrollment application, but also to be certified as meeting the Medicare health and safety standards.   The CCN is also used for submitting and reviewing the hospital’s cost reports.  The CCN number used to be called the "provider number," but with the advent of the statutorily mandated National Provider Identifier (NPI) number for claims processing, the CCN now plays a different role within the Medicare program. How does a hospital get a CCN? A hospital that seeks to participate in the Medicare program must first submit Form CMS 855A, Medicare Enrollment Application for Institutional Providers, to its regional Medicare Administrative Contractor or legacy Fiscal Intermediary.  Once the application is reviewed by the MAC/FI and recommended for approval to the CMS Regional Office, the hospital must then demonstrate its compliance with the Hospital Conditions of Participation through a survey, and, in the case of specialized hospitals, with other Federal requirements as well.  Once it has demonstrated this, the CMS Regional Office will assign an effective date for the Medicare provider agreement and issue the CCN.   Even if the hospital changes ownership, it will retain the same CCN, so long as the new owners assume the Medicare provider agreement.  However, there are circumstances when an existing hospital that has participated in Medicare must be treated as a new provider, undergoing a new enrollment process and assignment of a new CCN.  The CMS determines the requirements and process governing the enrollment of a hospital in Medicare and assignment of a CCN.  Additionally, CMS will change the CCN if the hospital changes its type of Medicare hospital classification, such as when a short term acute care hospital converts to a Long Term Care Hospital. Will all "provider-based" departments, satellites or remote locations under a hospital’s CCN be included in the hospital’s survey? Yes, all "provider-based departments," provider-based remote locations" and "satellites" of a provider covered under a hospital’s CCN will be subject to inclusion in the  hospital’s survey.  The following definitions from the CMS regulations may help to clarify "Department of a provider means a facility or organization that is either created by, or acquired by, a main provider for the purpose of furnishing health care services of the same type as those furnished by the main provider under the name, ownership, and financial and administrative control of the main provider, in accordance with the provisions of this section. A department of a provider comprises both the specific physical facility that serves as the site of services of a type for which payment could be claimed under the Medicare or Medicaid program, and the personnel and equipment needed to deliver the services at that facility. A department of a provider may not by itself be qualified to participate in Medicare as a provider under §489.2 of this chapter, and the Medicare conditions of participation do not apply to a department as an independent entity. For purposes of this part, the term "department of a provider" does not include an RHC or, except as specified in paragraph (n) of this section, an FQHC."  Provider-based departments do not include those that perform functions necessary for the successful operation of the providers but do not furnish services of a type for which separate payment could be claimed under Medicare or Medicaid. "Remote location of a hospital means a facility or an organization that is either created by, or acquired by, a hospital that is a main provider for the purpose of furnishing inpatient hospital services under the name, ownership, and financial and administrative control of the main provider, in accordance with the provisions of this section. A remote location of a hospital comprises both the specific physical facility that serves as the site of services for which separate payment could be claimed under the Medicare or Medicaid program, and the personnel and equipment needed to deliver the services at that facility. The Medicare conditions of participation do not apply to a remote location of a hospital as an independent entity. For purposes of this part, the term "remote location of a hospital" does not include a satellite facility. . ." "Satellite facility is a part of a hospital that provides inpatient services in a building also used by another hospital, or in one or more entire buildings located on the same campus as buildings used by another hospital, or in one or more entire buildings located on the same campus as buildings used by another hospital."  Satellites are part of an Inpatient Prospective Payment System (IPPS)-excluded hospital, or part of an IPPS-excluded unit of an IPPS hospital and the satellite is always co-located with an unrelated hospital. CCN stands for CMS (Centers for Medicare and Medicaid Services) Certification Number. A CCN uniquely identifies a reporting entity. It may encompass multiple facilities.

3 Measure intent: What is the episode of care?
Most inpatient measures are looking for data encompassed in a single episode of care: An episode of care is defined as the health care services given during a certain period of time, usually during a hospital stay (e.g., from the day of arrival or admission to the day of discharge). Source: Specifications Manual for National Hospital Inpatient Quality Measures For a patient who is admitted to inpatient care, the episode of care can include care provided in the ED and while in observation status, prior to the inpatient admission When measuring Emergency Department processes, what is the episode of care?

4 Part I. ED-1 and ED-2

5 Measure intent – ED-1 and ED-2
ED-1 (CMS55) Median Time from ED Arrival to ED Departure for Admitted ED Patients ED-2 (CMS111) Median Admit Decision Time to ED Departure Time for Admitted Patients Reducing the time patients remain in the emergency department (ED) can improve access to treatment and increase quality of care. Reducing this time potentially improves access to care specific to the patient condition and increases the capability to provide additional treatment. Improvement noted as a decrease in the median value. ED-1 (CMS55) Median Time from ED Arrival to ED Departure for Admitted ED Patients Reducing the time patients remain in the emergency department (ED) can improve access to treatment and increase quality of care. Reducing this time potentially improves access to care specific to the patient condition and increases the capability to provide additional treatment. Improvement noted as a decrease in the median value. Calculate the ED encounter duration in minutes for each ED encounter in the measure population; report the median time for all calculations performed. Initial Population: Inpatient Encounters ending during the measurement period with Length of Stay (Discharge Date minus Admission Date) less than or equal to 120 days. Measure Population: Inpatient Encounters preceded by an emergency department visit. ED-2 (CMS111) Median Admit Decision Time to ED Departure Time for Admitted Patients Calculate the duration in minutes between the Decision to Admit time and the discharge time for each ED encounter in the measure population; report the median time for all calculations performed. Measure Population: Inpatient Encounters where the decision to admit was made during the preceding emergency department visit. ED-3 (CMS32) Median Time from ED Arrival to ED Departure for Discharged ED Patients Calculate the ED encounter duration at the facility in minutes for each ED encounter in the measure population; report the median time for all calculations performed. Initial Population: Emergency department encounters discharged during the measurement period. Measure Population: Emergency department encounters discharged during the measurement period.

6 Measure design – ED-1 and ED-2
ED-1 (CMS55) ED-2 (CMS111) Measure Item Count Encounter, Performed: Encounter Inpatient Initial Population Inpatient Encounters ending during the measurement period with Length of Stay (Discharge Date minus Admission Date) less than or equal to 120 days. Measure Population Inpatient Encounters preceded by an emergency department visit. Inpatient Encounters where the decision to admit was made during the preceding emergency department visit. ED-1 (CMS55) Median Time from ED Arrival to ED Departure for Admitted ED Patients Reducing the time patients remain in the emergency department (ED) can improve access to treatment and increase quality of care. Reducing this time potentially improves access to care specific to the patient condition and increases the capability to provide additional treatment. Improvement noted as a decrease in the median value. Calculate the ED encounter duration in minutes for each ED encounter in the measure population; report the median time for all calculations performed. Initial Population: Inpatient Encounters ending during the measurement period with Length of Stay (Discharge Date minus Admission Date) less than or equal to 120 days. Measure Population: Inpatient Encounters preceded by an emergency department visit. ED-2 (CMS111) Median Admit Decision Time to ED Departure Time for Admitted Patients Calculate the duration in minutes between the Decision to Admit time and the discharge time for each ED encounter in the measure population; report the median time for all calculations performed. Measure Population: Inpatient Encounters where the decision to admit was made during the preceding emergency department visit. ED-3 (CMS32) Median Time from ED Arrival to ED Departure for Discharged ED Patients Calculate the ED encounter duration at the facility in minutes for each ED encounter in the measure population; report the median time for all calculations performed. Initial Population: Emergency department encounters discharged during the measurement period. Measure Population: Emergency department encounters discharged during the measurement period. Measure Population = AND: Initial Population AND NOT: "Occurrence A of Encounter, Performed: Emergency Department Visit" <= 6 hour(s) ends before or concurrent with start of "Encounter, Performed: Encounter Inpatient"

7 Issue Details – ED-1 and ED-2
CQM-1475 ED-1 (CMS55), ED-2 (CMS111) If a patient arrived in an emergency department in CCN 1 and is later discharged and readmitted to an IP unit in CCN 2, should the ED measure result be attributed to CCN 1? CCN 2? Or neither? Since the measure is in reference to the facility and the facility's ED, it's unclear whether or not the measure result should be attributed to CCN 2 (the IP CCN) since that is the "facility" even though the ED they came from in CCN 1 was not a part of that same facility. CQM-1499 ED-3 (CMS32) If a patient is arrived and discharged from an emergency department in CCN 1, and is admitted as an inpatient in CCN 2 within 6 hours, should this exclude them from the CMS 32 measure? The criteria in the specification for the measure population of CMS 32, which says “AND NOT: "Occurrence A of Encounter, Performed: Emergency Department Visit" <= 6 hour(s) ends before start of "Encounter, Performed: Encounter Inpatient"”, does not state whether the IP encounter must be in the same CCN as the ED encounter for this exclusion. Such a patient would seem to meet the spirit of stratification 3 - Transferred to Another Acute Care Facility, but it is unclear whether they should in fact be excluded based on becoming an Inpatient within 6 hours of the ED visit. Similarly, how would you define a "facility" in regards to this measure logic? Could it be multiple physical buildings, making it very similar/equivalent to a CCN? Or is each hospital building considered a separate facility in regards to these measures? Solution: You may or may not know if the Inpatient Encounter took place, if it took place at a hospital that was in a different CCN. It just depends on what information was available in the reporting CCN’s system. The definition of “facility” will depend on the way the enrollment is done for the provider’s CMS Certification Number (CCN). Source: The Medicare program allows considerable flexibility to hospital systems to define the "boundaries" of a participating hospital. As an example, a system that owns four "hospitals" in a specified geographic area may choose to have each hospital separately enrolled in Medicare, or, if it satisfies applicable Medicare rules, it can enroll them as one multi-campus hospital. In the first instance, each of the four hospitals would have its own CCN, and each would be required to comply separately with the CoPs. In the second instance, the four facilities would each be campuses of one hospital with one CCN, and together they would have to comply with the CoPs as one hospital. The hospital system, not the CMS, makes the decision on the manner in which it enrolls the facilities, but once it has done so, it must be surveyed and accredited in the same manner. Impact: Impacts ED populations depending on whether or not CCNs are considered completely independent of one another in regards to the measure logic. CQM-1475 ED-1 (CMS55), ED-2 (CMS111) If a patient arrived in an emergency department in CCN 1 and is later discharged and readmitted to an IP unit in CCN 2, should the ED measure result be attributed to CCN 1? CCN 2? Or neither? Since the measure is in reference to the facility and the facility's ED, it's unclear whether or not the measure result should be attributed to CCN 2 (the IP CCN) since that is the "facility" even though the ED they came from in CCN 1 was not a part of that same facility. Solution: These two measures are measuring inpatient encounters that were preceded by an emergency department visit that completed within an hour before the inpatient encounter began. It is possible that CCN 2 is reporting the measure even though the duration in the ED and the duration to admit decision reflects the care process at a different CCN where the ED visit actually occurred (CCN 1). Impact: Uncertainty in where to attribute measure result. (Inaccurate results because two different things may be being measured: ED process at CCN1 mixed with ED process at CCN2.)

8 Episode of Care Scenarios
Which ED visits will be measured for these two hospitals, CCN#1 and CCN#2? Arrival to the hospital (CCN #1) Discharge from inpatient care Admission at CCN#1, through ED at CCN#1 ED Inpatient Arrival to the hospital (CCN #2) Not all inpatient admissions come from ED with same CCN Admission at CCN#2, through ED at CCN#1 ED Inpatient Arrival to the hospital (CCN #2) Admission at CCN#2, through ED at CCN#2 ED Inpatient Episode of care

9 Episode of Care Scenarios
The design of ED-1 and ED-2 will not include these ED visits in the IP for CCN#1 Arrival to the hospital (CCN #1) Discharge from inpatient care Data in the EHR at CCN#1 Admission at CCN #1, through ED at CCN #1 ED Inpatient The ED measure for CCN#1 does not include all of its ED Visit data. Arrival to the hospital (CCN #2) Not all inpatient admissions come from ED with same CCN Admission at CCN #2, through ED at CCN #1 ED Inpatient What is the impact of the current measure design for hospitals that only admit patients from their own ED (same CCN)? What is the impact of the current measure design for hospitals that admit patients from their own ED (same CCN) and other EDs (not same CCN)? To what extent do these issues impact the accuracy or usefulness of the CQM results? Arrival to the hospital (CCN #2) Admission at CCN #2, through ED at CCN #2 ED Inpatient Data in the EHR at CCN#2 Does not include CCN#1 ED visit Episode of care

10 Episode of Care Scenarios
The design of ED-1 and ED-2 will include these ED visits in the MP for CCN#2, but how does that affect the mean scores for CCN#2’s ED process? Arrival to the hospital (CCN #1) Discharge from inpatient care Data in the EHR at CCN#1 Admission at CCN #1, through ED at CCN #1 ED Inpatient The ED measure for CCN#2 includes ED Visit data that effects their performance. Arrival to the hospital (CCN #2) Not all inpatient admissions come from ED with same CCN Admission at CCN #2, through ED at CCN #1 ED Inpatient Arrival to the hospital (CCN #2) Admission at CCN #2, through ED at CCN #2 ED Inpatient Assume the EHR at CCN#2 consumed a Transition of Care document from the ED visit at CCN#1 and now CCN#2 has data in their EHR about the prior ED Visit. Data in the EHR at CCN#2 Does include CCN#1 ED visit Episode of care

11 Part 2. ED-3

12 Measure intent – ED-3 ED-3 (CMS32) Median Time from ED Arrival to ED Departure for Discharged ED Patients Reducing the time patients remain in the emergency department (ED) can improve access to treatment and increase quality of care. Reducing this time potentially improves access to care specific to the patient condition and increases the capability to provide additional treatment. Improvement noted as a decrease in the median value. ED-1 (CMS55) Median Time from ED Arrival to ED Departure for Admitted ED Patients Reducing the time patients remain in the emergency department (ED) can improve access to treatment and increase quality of care. Reducing this time potentially improves access to care specific to the patient condition and increases the capability to provide additional treatment. Improvement noted as a decrease in the median value. Calculate the ED encounter duration in minutes for each ED encounter in the measure population; report the median time for all calculations performed. Initial Population: Inpatient Encounters ending during the measurement period with Length of Stay (Discharge Date minus Admission Date) less than or equal to 120 days. Measure Population: Inpatient Encounters preceded by an emergency department visit. ED-2 (CMS111) Median Admit Decision Time to ED Departure Time for Admitted Patients Calculate the duration in minutes between the Decision to Admit time and the discharge time for each ED encounter in the measure population; report the median time for all calculations performed. Measure Population: Inpatient Encounters where the decision to admit was made during the preceding emergency department visit. ED-3 (CMS32) Median Time from ED Arrival to ED Departure for Discharged ED Patients Calculate the ED encounter duration at the facility in minutes for each ED encounter in the measure population; report the median time for all calculations performed. Initial Population: Emergency department encounters discharged during the measurement period. Measure Population: Emergency department encounters discharged during the measurement period.

13 Measure design – ED-3 Measure ED-3 (CMS32) Measure Item Count
Encounter, Performed: Emergency Department Visit Initial Population Emergency department encounters discharged during the measurement period. Measure Population ED-1 (CMS55) Median Time from ED Arrival to ED Departure for Admitted ED Patients Reducing the time patients remain in the emergency department (ED) can improve access to treatment and increase quality of care. Reducing this time potentially improves access to care specific to the patient condition and increases the capability to provide additional treatment. Improvement noted as a decrease in the median value. Calculate the ED encounter duration in minutes for each ED encounter in the measure population; report the median time for all calculations performed. Initial Population: Inpatient Encounters ending during the measurement period with Length of Stay (Discharge Date minus Admission Date) less than or equal to 120 days. Measure Population: Inpatient Encounters preceded by an emergency department visit. ED-2 (CMS111) Median Admit Decision Time to ED Departure Time for Admitted Patients Calculate the duration in minutes between the Decision to Admit time and the discharge time for each ED encounter in the measure population; report the median time for all calculations performed. Measure Population: Inpatient Encounters where the decision to admit was made during the preceding emergency department visit. ED-3 (CMS32) Median Time from ED Arrival to ED Departure for Discharged ED Patients Calculate the ED encounter duration at the facility in minutes for each ED encounter in the measure population; report the median time for all calculations performed. Initial Population: Emergency department encounters discharged during the measurement period. Measure Population: Emergency department encounters discharged during the measurement period. Measure Population = AND: Initial Population AND NOT: "Occurrence A of Encounter, Performed: Emergency Department Visit" <= 6 hour(s) ends before or concurrent with start of "Encounter, Performed: Encounter Inpatient"

14 Issue Details – ED-3 CQM-1499 ED-3 (CMS32) The criteria in the specification for the measure population of CMS 32, which says “AND NOT: "Occurrence A of Encounter, Performed: Emergency Department Visit" <= 6 hour(s) ends before start of "Encounter, Performed: Encounter Inpatient"”, does not state whether the IP encounter must be in the same CCN as the ED encounter for this exclusion. Such a patient would seem to meet the spirit of stratification 3 - Transferred to Another Acute Care Facility, but it is unclear whether they should in fact be excluded based on becoming an Inpatient within 6 hours of the ED visit. Similarly, how would you define a "facility" in regards to this measure logic? Could it be multiple physical buildings, making it very similar/equivalent to a CCN? Or is each hospital building considered a separate facility in regards to these measures? CQM-1499 ED-3 (CMS32) If a patient is arrived and discharged from an emergency department in CCN 1, and is admitted as an inpatient in CCN 2 within 6 hours, should this exclude them from the CMS 32 measure? The criteria in the specification for the measure population of CMS 32, which says “AND NOT: "Occurrence A of Encounter, Performed: Emergency Department Visit" <= 6 hour(s) ends before start of "Encounter, Performed: Encounter Inpatient"”, does not state whether the IP encounter must be in the same CCN as the ED encounter for this exclusion. Such a patient would seem to meet the spirit of stratification 3 - Transferred to Another Acute Care Facility, but it is unclear whether they should in fact be excluded based on becoming an Inpatient within 6 hours of the ED visit. Similarly, how would you define a "facility" in regards to this measure logic? Could it be multiple physical buildings, making it very similar/equivalent to a CCN? Or is each hospital building considered a separate facility in regards to these measures? Solution: You may or may not know if the Inpatient Encounter took place, if it took place at a hospital that was in a different CCN. It just depends on what information was available in the reporting CCN’s system. The definition of “facility” will depend on the way the enrollment is done for the provider’s CMS Certification Number (CCN). Source: The Medicare program allows considerable flexibility to hospital systems to define the "boundaries" of a participating hospital. As an example, a system that owns four "hospitals" in a specified geographic area may choose to have each hospital separately enrolled in Medicare, or, if it satisfies applicable Medicare rules, it can enroll them as one multi-campus hospital. In the first instance, each of the four hospitals would have its own CCN, and each would be required to comply separately with the CoPs. In the second instance, the four facilities would each be campuses of one hospital with one CCN, and together they would have to comply with the CoPs as one hospital. The hospital system, not the CMS, makes the decision on the manner in which it enrolls the facilities, but once it has done so, it must be surveyed and accredited in the same manner. Impact: Impacts ED populations depending on whether or not CCNs are considered completely independent of one another in regards to the measure logic. CQM-1475 ED-1 (CMS55), ED-2 (CMS111) If a patient arrived in an emergency department in CCN 1 and is later discharged and readmitted to an IP unit in CCN 2, should the ED measure result be attributed to CCN 1? CCN 2? Or neither? Since the measure is in reference to the facility and the facility's ED, it's unclear whether or not the measure result should be attributed to CCN 2 (the IP CCN) since that is the "facility" even though the ED they came from in CCN 1 was not a part of that same facility. Solution: These two measures are measuring inpatient encounters that were preceded by an emergency department visit that completed within an hour before the inpatient encounter began. It is possible that CCN 2 is reporting the measure even though the duration in the ED and the duration to admit decision reflects the care process at a different CCN where the ED visit actually occurred (CCN 1). Impact: Uncertainty in where to attribute measure result. (Inaccurate results because two different things may be being measured: ED process at CCN1 mixed with ED process at CCN2.)

15 Episode of Care Scenarios
The design of ED-3 will include these ED visits in the IP and MP for CCN#1 Arrival to the hospital (CCN #1) Discharge from inpatient care Data in the EHR at CCN#1 Admission at CCN #1, through ED at CCN #1 ED Inpatient > 6 hrs. ED Inpatient ED These ED Visits really should be excluded from the MP for CCN#1 Arrival to the hospital (CCN #2) Not all inpatient admissions come from ED with same CCN Admission at CCN #2, through ED at CCN #1 ED Inpatient What is the impact for EDs that transfer their patients to other facilities for hospitalization? To what extent do these issues impact the accuracy or usefulness of the CQM results? Arrival to the hospital (CCN #2) Episode of care ED Inpatient Admission at CCN #2, through ED at CCN #2 ED > 6 hrs. Inpatient ED Episode of care

16 Considerations Are we defining the right Measure Population?
ED-1 (CMS55) ED-2 (CMS111) ED-3 (CMS32) Measure Item Count Encounter, Performed: Encounter Inpatient Encounter, Performed: Emergency Department Visit Initial Population Inpatient Encounters ending during the measurement period with Length of Stay (Discharge Date minus Admission Date) less than or equal to 120 days. Emergency department encounters discharged during the measurement period. Measure Population Inpatient Encounters preceded by an emergency department visit. Inpatient Encounters where the decision to admit was made during the preceding emergency department visit. Are we using the correct Measure Item Count? Are we defining the right Initial Population? Inpatient Encounters? or ED Visits? Are we defining the right Measure Population? Inpatient Encounters preceded by an ED Visit? or ED Visits with Encounter Discharge Disposition Code indicating an inpatient hospital (or some defined value set)?

17 Recommendations All measures intended to assess ED Visit process throughput should use the ED Visit as the Measure Item Count Eliminates use of the Inpatient Encounter to find the ED Visits Affects ED-1 and ED-2 Achieves greater consistency across all three ED measures To measure only ED Visits that are not part of a larger episode of care, define the Measure Population Exclusion using the Encounter, Performed: Discharge Disposition attribute Eliminates logic that depends on availability of data about subsequent encounters which may not be present in the EHR for the CCN being assessed. Affects ED-1, ED-2, ED-3 May create opportunity to improve how we address the issues associated with episodes of care that include multiple departments (“encounters”) before ending up as an Inpatient Encounter, like ED to Cath Lab to Inpatient, or ED to Observation Unit to Inpatient. (paradigm shift: episode of care = a set of encounters not limited by “facility”) Clarify the meaning of the term “facility” in the measure definition to better explain how the CCN id effects the notion of “facility”? Encounter Activity (V2) [encounter: identifier urn:hl7ii: : (open)] This sdtc:dischargeDispositionCode SHALL contain exactly which SHALL be selected from ValueSet NUBC UB-04 FL17-Patient Status (code system ) DYNAMIC or, if access to NUBC is unavailable, from CodeSystem HL7 Discharge Disposition (CONF: ). This sdtc:dischargeDispositionCode SHALL contain exactly which SHALL be either CodeSystem: NUBC OR CodeSystem: HL7 Discharge Disposition (CONF: ). Quality Attribute Name: Discharge Status (attribute) Quality Datatype Pattern ID: CDA Template Name and CDA Element Xpath: Encounter Activities /.../encounter/sdtc:dischargeDispositionCode CDA Template ID: urn:hl7ii: : Wild Goose Chase to find this value set: VALUE SET: USEncounterDischargeDisposition ( ) Version date: 3/26/2014 Description: Supported Code Systems: nubc-UB92 ( ) Contains 1 child of type allCodes Bound to Domains: EncounterDischargeDisposition (CWE) in US (United States of America) Version history: 2014T1_ _ [Vocabulary (Woody Beeler)] Substantive Change - Lock all vaue sets untouched since to trackingId 2014T1_2014_03_26

18 Discussion


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