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When do Medicare Payment Policies Potentially Threaten Patient Safety? A Potential Example: Proposed Payment Policies for Measurement of 25-OH Vitamin D Levels

2009-02-26 16:32:48
By: Dr. Richard Hellman

A draft Local Coverage Determination (LCD) was issued by one of the regional CMS carriers this month on payment codes for calcifediol (25-OH Vitamin D-3) levels. In this LCD, they delineated the diagnosis codes that would be paid for if the 25-OH vitamin D level was assayed. The covered diagnoses included only chronic kidney disease, hypercalcemia, and disorders of phosphorous metabolism, osteomalacia, and active rickets.

This highly restricted list of indications stimulated immediate responses from a number of important organizations, including AACE. In the AACE response, the letter correctly pointed out the wide variety of conditions in which not diagnosing abnormally low vitamin D levels would put the patient at considerable risk for additional morbidity and mortality. I could not agree more with the AACE response.

But why should a website on patient safety talk about public policy? Because this policy will threaten patient safety, and it brings out the dilemma all of us must deal with each day. Health care must be affordable and costs must be carefully scrutinized. But building systems of care that are safer for our patients has real costs. It is not enough to be in favor of safer systems of care, we must also pay for them. We cannot run a hospital safely without numbers of well-trained nurses. We cannot expect to run a high-quality, safe, evidence-based outpatient care system when we take away key tools, such as 25-OH vitamin D testing, which is the best test for Vitamin D deficiency, and used every day in diagnosis and management of the disorders that need our care. The increased use of vitamin D assays today reflect a relatively recent increase in the understanding of the key importance of vitamin D levels in many conditions we treat, not just in bone disease, such as osteoporosis, but also in hyperthyroidism, diabetes, impaired glucose tolerance, in patients with severe muscle weakness and aching, certain cancers, and in some autoimmune disorders.

The story of osteoporosis care in the United States is particularly relevant to understand when it comes to the discussions surrounding 25-OH vitamin D testing. Osteoporosis is an extremely common condition that has been grossly undiagnosed and under-treated in our country for many years. Many of the hip and vertebral fractures that occur every year are preventable, but this proposed policy of restricting use of 25-OH vitamin D testing will be likely to increase the number of fractures, at a time where there already is an unacceptably high frequency of these fractures. In addition, not only will this policy worsen the outcomes of many patients with osteoporosis, but it will likely contribute to a large number of other problems for which the Medicare population is at risk. Since the wealthier patients will be more likely to afford to be tested for vitamin D deficiency when it is clearly needed, we are now introducing a serious threat mostly to our most vulnerable populations, a policy that both worsens patient safety and is inequitable and discriminatory. It will be the poorest citizens, particularly our minority patients, who will probably be most at risk for under-diagnosis and under-treatment of vitamin D deficiency related problems

The public may not be aware of what we are talking about. There are scientific studies to show that low 25-OH vitamin D levels are associated with an increased risk of muscle weakness, of falls, and an increased risk of hip and vertebral fractures when they do fall. But the effects of vitamin D deficiency are far more extensive than most people realize. For example, low vitamin D levels increase the risk of tuberculosis and hamper the ability to treat it. The risk for prostate, colon, non-Hodgkin’s lymphoma, melanoma, and breast cancers increases in the presence of vitamin D deficiency. Many medications, taken for other reasons, may cause low levels of the vitamin. Also, other diseases, such as hyperthyroidism and malabsorption, may also lower the levels of vitamin D. The deficiency of vitamin D may induce heart failure, worsen glucose intolerance, and increase the risk of many autoimmune diseases, including multiple sclerosis. Depressive symptoms worsen in the presence of vitamin D deficiency. In the United States, osteoporosis is very frequently associated with vitamin D deficiency, and in the presence of vitamin D lack, biphosphonate treatment is not enough. Appropriate calcium and vitamin D replacement must also be given and monitored if we are to reduce the risk of fragility fractures.

Policy makers understand that payment policies are very powerful tool for changing physician ordering behavior, and may be very useful in some settings, but they may not always realize that it is also a very blunt tool, which can cause great harm if improperly used. In this case, the scientific evidence, nicely summarized by M. Holick (1) in the New England Journal of Medicine in 2007, clearly shows the risk of vitamin D deficiency to all patients, both young and old, at all stages of life, but particularly in our ageing populations.

Five years ago, few physicians understood what we understand today about the ubiquity of vitamin D metabolites in our tissues and the central importance of those to our health. It may be that part of the issue is that the policy makers are not aware of the tremendous strides in the knowledge of vitamin D metabolism that we have made. But we know today that to restrict the ability of doctors to be able to perform this test on those who need it because CMS will not pay for it will have a dangerous effect on poorer and more vulnerable patients.

Surely the policy makers can do better and expand the list of approved uses of 25-OH vitamin D levels to one that is in keeping with the current scientific evidence.

REFERENCES:

Holick MF. Vitamin D deficiency, N England J Med, 2007 July 19; 357(3): 266-281

Leave a Comment

There are 7 comments

Prasanna Rao-Balakrishna – UK

July 14, 2009 - 17:23

Subject: Preventing Hypoglycaemia is as important as the tight glycaemic control

Preventing hypoglycaemia is as important as the tight glycaemic control. It is important to note that glycaemic control depends on the insulin regimen, patient's own counter regulatory hormone response & insulin resistance status, the calorie intake, frequency of testing for blood glucose, interpretation and acting on the results. During acute illness it is not possible to control the counter-regulatory hormone response and the insulin resistance status, but with adequate training, frequent testing and appropriate structured response should be possible, thereby preventing a hypoglycaemia. A trial which focuses as much on hypoglycaemia avoidance as well as tight glycaemic control is needed.

Reply to Prasanna Rao-Balakrishna

Richard Hellman MD

July 16, 2009 - 11:25

Subject: RE: Preventing Hypoglycaemia is as important as the tight glycaemic control

Dr Rao-Balakrishna makes a very interesting suggestion, that preventing hypoglycemia is as important as the tight glycemic control, and suggests a trial that focuses on two end-points, the avoidance of hypoglycemia as a co-equal goal in importance to tight glycemic control.

In fact, there is a great deal we do not know about hypoglycemia in critically ill states, and it is far from clear what the short and long term consequences are of mild, moderate, or even brief periods of severe ypoglycemia for critically ill patients. We do know that severe hypoglycemia can be a marker for increased mortality, as it was clearly shown in the VADT trial, but interestingly, those deaths did not usually occur during the hypoglycemic episodes, and the relationship between severe hypoglycemia and subsequent mortality was strongest in the conventional therapy group, suggesting that the hypoglycemic events may have been a consequence of an underlying vulnerability rather than the cause of mortality.

One of the limitations of an approach focused just on the outcomes of glycemia is that from the patients' standpoint, the most important issues are their clinical outcomes: mortality, morbidity, and disability. In contrast, those outcomes may not match the relative frequency of hypoglycemia at all. For example, there is a disconnect between the very high frequency of hypoglycemia in the Van Den Berghe RCT's in critical care published in 2001, 2006, and 2009. Both the surgical ICU study of 2001 and the 2009 pediatric studies showed very excellent outcomes with respect to mortaliy and morbidity in the presence of relatively frequent hypoglycemia.

I again would like to thank Dr Rao-Blakrishna for pointing us again to this very unsettled issue of the importance of hypoglycemia prevention, for the debate as to what we can and should do rages on. There are many creative ideas that have been proposed, but we need more data to guide us as to how to obtain the best clinical outcomes with the tools we have without either unacceptably high levels of hypoglycemia or hyperglycemia.

Richard Hellman MD
Editor-In-Chief
Patient Safety Exchange Website

MRR – Texas

March 31, 2009 - 16:29

Subject: NICE_SUGAR

Several interesting points came to mind when I reviewed the NICE-SUGAR study; the degree of severe hypoglycemia, the degree of cardiovascular mortality, the conventional group’s blood glucose levels are significantly lower than the vast majority of other outcome studies, and the number of severe septic patients in the intensive control branch of the study. According to the 2008 sepsis guidelines, the glycemic control target level for the septic patient is already in question and perhaps sepsis should be an exclusion criteria?

I was tasked with the development and oversight of a Tight Glycemic Control Program pilot study from May 2006 through April 2008 for a South Texas community hospital/level 2 trauma center. This included a 14 bed CCU, 12 bed M/S ICU and 12 bed trauma ICU as well as 4 M/S wards. Clinical inertia was our most difficult element to overcome and for the most part this was never accomplished. Clinical inertia was not only evident on physician's part, but also administration, nursing, nutritional services, pharmacy, and the patients themselves. Accountability to noncompliance to protocols was lacking as well. The philosophy that inpatient glycemic control was not necessarily treating diabetes, yet acute hyperglycemia was never fully accepted. When results like ACCORD, ADVANCE, and VADT were released, I would usually take the phone off the hook and leave the hospital because those wbeepdo not support inpatient glycemic control would come out en mass wishing to compare apples to oranges. That is not necessarily the case with NICE-SUGAR. In our Trauma ICU, where support was highest, for the entire year of 2007, we had only 7% BG > 200mg/dL, less than 2% hypoglycemia under 50 mg/dL, and nearly 75% BG between 80 - 150 mg/dL.

Overall, I applaud the NICE-SUGAR research team for a job very well done and thank them for their contribution to this ongoing discussion. I do support further research to differentiate specific glycemic control target ranges for specific diagnosis, but I too fear this could cause a pendulum swing in the opposite direction resulting in less facilities participating in inpatient glycemic control resulting in less data for differentiation.

NISSIM GABAY – VENEZUELA

March 26, 2009 - 15:25

Subject: NICE -SUGAR

I think that the central goal of the ADA/AACE impatient glucose targets is safe with the protocols .
Hospitals should have protocols in place for using insulin to treat and prevent hyperglycemia.
Subcutaneous insulin may be used for both purposes in most noncritically ill patients, whereas intravenous infusion of
insulin is preferred in critically ill patients.
Be careful with this trial [NICE -SUGAR] to overcome clinical inertia.

Dr. Orlin Sergev – Charleston, SC

March 16, 2009 - 16:28

Subject:

Dear Dr Hellman:
I enjoyed all the editorials on patients' safety that you have recently published. I think that they raise questions which we as physicians are not always open about. Safety itself is frequently a topic that we love to discuss but it's never our fault. In this connection, the article about overconfidence and medical errors is timely - especially, at this time of expected health care changes. Briefly, I do not think we as physicians are different from any other specialists in different areas. Lack of adequate knowledge in a special area is always a good reason to be noisy and seemingly overconfident. Most of us agree that the more you know the more you realize how much more you do not know. Overconfident behavior in front of outsiders seem to be the cover of ignorance. I think we have to improve medical education in order to make medical decisions safer. Just remember the pilot of the plane that landed in Hudson river - quiet professional on top of his performance. We in medical profession must lead in patients' safety. In order to do that we have to lead the health care reform. We have to regain our authority, responsibility and accountability. (accountability without authority and responsibility is meaningless - see Dr Hellman's article on Medicare). We have to lead the health education of the society - most of the tragic mistakes in life happen from ignorance. First and foremost, of course, we have to maintain the superiority in medical knowledge. We must improve the quality of medical education. Instead of multiple choice questions we have to put back in place the stern professor wbeepmade clinical judgements based on knowledge, experience, and gut feeling and set up a good personal example for the next generation of physicians. Pilot "Sully" did not read the manual and the guidelines how to handle the critical situation - all his life before, however, prepared him for the right on the spot decision. Decisions based on profound knowledge and experience are the safest! Let's start the health care reform with ourselves.
Do not stop learning and teaching your team about sound and safe medical practices. When we have achieved that, we can confidently go out and regain our authority over various bureaucracies (government agencies-Medicare, insurances, medical malpractice law, etc).

james t poulos – west lafayette in

March 03, 2009 - 15:09

Subject: NICE-SUGAR

There was an article in acta scandinavia in january that showed very little hypoglycemia when intensive therapy is done right! I came across the article on medlinx in mid January, but it was actually published in October 2008. authors: Kaukonen KM et al in acta anaethesiol scandinavia and titled severe hypoglycemia in intensive insulin therapy.

Reply to james t poulos

Dr Hellman

March 04, 2009 - 16:12

Subject: Further thoughts related to the NICE-SUGAR study

Dear Dr. Poulos,

Thank you for calling attention to the study by Kaukonen KM et al. Your excellent point adds to the discussion generated by the NICE-SUGAR study. Their preliminary data analysis showed that error by provider was the most common cause of hypoglycemia. Their data implied, as I stated in my recent editorial, that improving the training and performance of those managing the insulin infusions greatly decreases the threat of hypoglycemia.

In this study by Kaukonen, done at the Helsinki University Central Hospital in Helsinki, Finland, the authors evaluated the incidence of hypoglycemia in all patients treated in two intensive care units between February 2005 and June 2006. They showed that severe hypoglycemia during intensive insulin therapy was rare in clinical practice. Analyzing data for 1124 patients and 61,203 glucose measurements, they found 36 measurements of severe (≤ 2.2mmol/L) hypoglycemia in 25 patients, with an incidence of 0.06% of severe hypoglycemia.

They commented that the frequency of blood glucose monitoring correlated inversely with the frequency and magnitude of severe hypoglycemia. In surgical patients, it is of note that five of the six instances of hypoglycemia occurred when a nurse failed to comply with the protocol.

The Helsinki group’s observations are entirely in keeping with the preliminary data from the NICE-SUGAR study and make a good deal of common sense. When the rate of decrease of glucose is rapid, for example greater than 1mg/dl/minute, simple arithmetic can tell us when the next glucose determination needs to occur to be able to safely avoid severe hypoglycemia. But if the frequency of checking of glycemic levels is arbitrary, and set too low, then hypoglycemia is to be expected much more often. The Kaukonen group avoided this by making sure the blood glucose sampling was relatively frequent.

In our clinical practice setting as well, the principles of safe handling of insulin infusions have been:

1.frequent monitoring, always at least hourly in ICU settings, more often when dealing with lower glycemic levels;
2.intensive training of nurses to make them expert in understanding how best to use algorithms;
3.specific points at which prolonged hyperglycemia or hypoglycemia necessitates immediate consultation with the responsible physician;
4.review of data to indicate variations in performance and appropriate correction and retraining when appropriate.

We too have extensive experience over many years with the safe use of insulin infusions in inpatient settings with relatively rare severe hypoglycemic episodes and little morbidity.

The NICE-SUGAR study should provide important information. We should not get too far ahead of their forthcoming data, but there is already abundant data, such as the important study from Helsinki, which show us that with a safer system of care, more ambitious glycemic control is both achievable and safe.

Kaukonen KM et al. Severe hypoglycemia during intensive insulin therapy, Acta Anaesthesiol Scand. 2009 Jan;53(1):61-65. Epub 2008 Oct 20.