To the Editor The effectiveness of Centers for Medicare & Medicaid Services (CMS) performance-based payment strategies will shape efforts to improve the quality and value of care. Waters et al1 examined the effect of the Hospital-Acquired Conditions (HACs) Initiative, which denies incremental payment for 8 complications on 4 outcomes: central line–associated bloodstream infections (CLABSIs), catheter-associated urinary tract infections (CAUTIs), hospital-acquired pressure ulcers (HAPUs), and injurious inpatient falls. They found an association with reductions in CLABSIs and CAUTIs but not injurious falls or stage III/IV HAPUs. Waters et al concluded that there is less evidence that changing hospital processes affects these other 2 outcomes, but we believe this conclusion may be missing key factors.