Page 192 - CW E-Magazine (30-4-2024)

Special Report

ing Interoperability program (formerly already have available, which would or penalties could be phased-in ini-
the Medicare and Medicaid Electronic enhance transparency about existing tially for reporting the attestation mea-
Health Record Incentive Program). practices. sures or other hospital information,
More specifically, the HRSP could and then could be expanded to include
optimize new and existing authorities In addition, HHS says that MRAP manufacturer resilience ratings. Simi-
to link Medicare payments and/or pen- could provide HRSP with information larly, the incentives and/or penalties
alties to hospitals based on a hospital about the reliability of manufacturers could be based on the scorecard, or
scorecard that would be a combination that hospitals purchase from, thus could be based on achieving a certain
of attestations and ratings refl ecting the expanding the hospital scorecard to base rating or improvements in scorecard
hospitals’ achievement and progress in purchasing decisions on manufacturer ratings or other factors such as size or
adopting practices that promote supply resilience as well as price. As a whole, volume of the hospital, with attention
chain resilience or prevent shortages. the scorecard developed by the HRSP to smaller hospitals that lack the pur-
Hospital attestations or other hospital could include lagging and leading chasing power of larger hospitals or
resilience-oriented activities that could indicators of practices that promote sup- health systems. HRSP payment and/
be considered include hospital inven- ply chain resilience among hospitals, or penalty amounts would have to be
tory management practices (stockpiling middlemen, and manufacturers. HRSP large enough to incentivize change and
or buffer stocks) and hospital contract- could develop the scorecard for pay- cover the cost and benefi ts of engaging
ing practices with middlemen (e.g., ments and/or incentives for an initial in practices that promote supply chain
inclusion of effective failure-to-supply set of drugs that are considered eligible resilience, while being fi scally respon-
clauses, minimum purchasing volume and eventually expand to other pro- sible to the program. If successful, the
requirements, long-term contracts) ducts prioritized by MRAP or CMS. HRSP could be expanded to the out-
that promote supply chain resilience. patient setting or to include medical
Attestation measures could also consider Under the HHS proposal, the devices. “Ultimately, this would promote
whether the hospital purchases from scorecard could be scaled based on investment in resiliency at the manu-
diverse sources, including domestic various factors, including but not limi- facturer level, and facilitate market
ones, thus supporting redundancy in the ted to hospital size, hospital attesta- participation or support market entry
market. The attestation measures could tions, and hospitals’ performance on for multiple or more diversifi ed pro-
be based on information that facilities the hospital scorecard. Incentives and/ ducers,” said HHS in its white paper.

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192 Chemical Weekly April 30, 2024

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