Completion won’t lower your CMS penalties. Competency will.
HAC, readmissions and value-based purchasing all adjust Medicare payments on the same thing — the clinical behaviors your workforce either performs reliably or doesn’t. Size the dollars on the line against your own revenue.
1%
Medicare payments cut — HAC, worst-performing quartile
3%
of base DRG payments — the readmissions penalty cap
3%
withheld and redistributed — value-based purchasing
The pattern
Three programs. The same competencies underneath.
HAC, HRRP and value-based purchasing read like three separate line items on your Medicare remittance. They aren’t. Each one adjusts your payments on the same clinical behaviors – infection prevention, medication safety, recognizing deterioration, and communication at discharge.
Training measured by completion can’t move any of them. Only reliable performance at the bedside does – the decision a clinician actually makes when it counts, not the module they finished.
The reframe
This is regulatory exposure – not a compliance cost.
The dollars HAC, HRRP and VBP take off your payments aren’t the price of the rules. They’re the price of a competency gap your own incident data already names — showing up where Medicare can see it.
Which changes the question. Not “did our staff complete the training,” but “did the decision at the bedside change” — and by how much.
Size it
Put in your own numbers.
Enter your Medicare inpatient revenue and your standing in each program. This sizes the Medicare dollars tied to clinical-competency performance — on public CMS rules, against your figures. It isn’t a claim about your scores.
Your CMS exposure
▶ How the three programs stack
HAC cuts 1% of Medicare payments for the worst-performing quartile. HRRP reduces base DRG payments up to 3% for excess readmissions. VBP withholds 2% of base DRG payments and redistributes it on performance across four equal domains — this tool sizes the two clinical domains (Safety and Clinical Outcomes).
Medicare dollars tied to clinical-competency performance
each year — the price of the competency gap
60%
Hoag Hospital — medication errors
Hoag built OMS scenarios around the medication-error patterns its own data flagged. Errors leading to harm fell 60%, and the result repeated in year two — the safety behavior under the HAC and VBP safety measures.
What changes
Train the behavior.
Measure it like a study.
OMS builds scenarios around the specific decisions where these penalties originate — sepsis recognition, medication safety, infection prevention, the discharge handoff — and captures how clinicians reason and where they make errors. Run as a quality-improvement project, with a named clinical endpoint measured pre and post against your own baseline, it produces behavior-change evidence leaders can actually stand behind.
At Carle Health, that approach was associated with sepsis-bundle compliance rising from 49% to 89% – the recognition-and-response behavior under the clinical-outcomes measures.
Common questions
Answered, plainly.
Request a Working session
Map your exposure to the competencies behind it.
We’ll connect your HAC, HRRP and VBP standing to the specific clinical behaviors your workforce can train to reliability – and set up the measurement against your own baseline.


