Then doctors filter what patients they take to guarantee these good outcomes. This is already done by some surgeons. Surgery is already a subset of medicine heavily judged on outcomes.
This is featured in the Doctor Strange movie, in fact. IIRC the good doctor is presented with a patient whose case is so difficult that he's one of the only people in the world with a chance at successfully performing the procedure they need—but he turns it down because he thinks the odds would still be too low, and it might hurt his record. I think there might also be a karmic turn with that when his hands get messed up—I wanna say there's a scene or short sequence of the same thing happening to him, at least implicitly.
Cherry picking and lemon dropping does happen in value-based systems, but there has been work to address the issue. No simple answer, but basically you pay doctors more for select patients.
Within the context of the article though, if one assumes greedy doctors, then essentially cooperating doctors can cooperate to refuse treatment N times, where N is an equilibrium between the lemon-picking bonus and never accepting any patients at all (and therefore never having any revenue), in order to get the system to label non-lemons as lemons.
I got the impression that the same phenomenon was present with driving instructors and driving test pass rates. If it's clear after a dozen or so lessons that they might not pass then say that you will stop teaching and suggest a different instructor.