Chief nursing officers’ perspectives on Medicare’s hospital-acquired conditions non-payment policy: implications for policy design and implementation

BACKGROUND: Preventable adverse events from hospital care are a common patient safety problem, often resulting in medical complications and additional costs. In 2008, Center for Medicare and Medicaid Services (CMS) implemented a policy, mandated by the Deficit Reduction Act of 2005, targeting a list of these ‘reasonably’ preventable hospital-acquired conditions (HACs) for reduced reimbursement. Extensive debate ensued about the potential adverse effects of the policy, but there was little discussion of its impact on hospitals’ quality improvement (QI) activities. This study’s goals were to understand organizational responses to the HAC policy, including internal and external influences that moderated the success or failure of QI efforts. METHODS: We employed a qualitative descriptive design. Representatives from 14 Nurses Improving Care of Health System Elders (NICHE) hospitals participated in semi-structured interviews addressing the impact of the HAC policy generally, and for two indicator conditions: central-line associated bloodstream infection (CLABSI) and catheter-associated urinary tract infection (CAUTI). Within-case analysis identified the key components of each institution’s response to the policy; across-case analysis identified themes. Exemplar cases were used to explicate findings. RESULTS: Interviewees reported that the HAC policy is one of many internal and external factors motivating hospitals to address HACs. They agreed the policy focused attention on prevention of HACs that had previously received fewer dedicated resources. The impact of the policy on prevention activities, barriers, and facilitators was condition-specific. CLABSI efforts were in place prior to the policy, whereas CAUTI efforts were less mature. Nearly all respondents noted that pressure ulcer detection and documentation became a larger focus stemming from the policy change. A major challenge was the determination of which conditions were ‘hospital-acquired.’ One opportunity arising from the policy has been the focus on nursing leadership in patient safety efforts. CONCLUSIONS: While the CMS’s HAC policy was just one of many factors influencing QI efforts, it may have served the important role of drawing attention and resources to the targeted conditions—particularly those not previously in the spotlight. The translational research paradigm is helpful in the interpretation of the findings, illustrating how the policy can advance prevention efforts for HACs at earlier phases of research translation as well as pitfalls associated with earlier phase implementation. To maximize their impact, such policies should consider condition-specific contextual factors influencing policy uptake and provide condition-specific implementation support.