How Would CMS' Proposed FY 2013 IPPS Rule Affect Quality Improvement, Reporting Efforts?
Apart from the federal government's efforts to more accurately distribute payments to healthcare providers and reduce administrative burden in the healthcare sector, the proposed rule also includes notable changes to quality reporting programs, including the Hospital Inpatient Quality Reporting, Hospital Value-Based Purchasing and Ambulatory Surgical Center Quality Reporting programs, as well as two new quality reporting programs.
Proposed changes to the Hospital Inpatient Quality Reporting Program
The measure set under this quality reporting program has grown dramatically from 10 quality measures in 2004 to the current set of 72 quality measures, which includes chart-abstract measures, claims-based measures, patient experience of care measures and more. However, CMS has proposed changes to reduce the number of measures from 72 to 59 for the FY 2015 payment determination and 60 for the FY 2016 payment determination. This proposal is intended to reduce the administrative burden on hospitals.
Other proposed changes are intended to maintain accurate collection and reporting of quality data. They include reducing the annual random validation sample from 800 hospitals to 400 hospitals and increasing the targeted sample to up to 200 hospitals to review potential reporting anomalies in FY 2014.
Proposed changes to the Hospital Value-Based Purchasing Program
While the FY 2014 VBP Program has already been finalized (a complete list of clinical process of care, patient experience of care and outcome measures for the FY 2014 VBP Program can be found on page 795 of the proposed rule), CMS has proposed to retain 12 of the 13 clinical process of care measures from the FY 2014 program for the FY 2015 program. CMS also proposed one new clinical process of care measure (AMI-10: Statin Prescribed at Discharge); two new outcomes measures (Central Line Associated Blood Stream Infection and the Patient Safety Indicator composite measure); and one more efficiency measure (Medicare Spending per Beneficiary) for FY 2015. Patient experience of care measures will remain the same.
Other proposed changes to the FY 2015 VBP Program include performance standards, including achievement thresholds and benchmarks for all proposed measures, as well as "floors" for all eight Hospital Consumer Assessment of Healthcare Providers and Systems dimensions.
CMS also set forth recommended changes to the FY 2016 VBP Program. This set of changes includes six new domains for quality measures: clinical care; person- and caregiver-centered experience and outcomes; safety; efficiency and cost reduction; care coordination; and community/population health.
Proposed changes to Hospital-Acquired Conditions
In conjunction with the CDC, CMS proposed adding two new conditions to the hospital-acquired condition payment provision list. The HAC payment provisions impact hospital payments for HACs that are high-cost, high-volume or both and could have been prevented through evidence-based measures. The two proposed conditions are "surgical site infection following cardiac implantable electronic device procedures" and "pneumothorax with venous catheterization."
CMS is also proposing to add two codes — 999.32 (Bloodstream infection due to central catheter) and 999.33 (Local infection due to central venous catheter) — to the existing Vascular Catheter-Associated Infection HAC category.
Proposed changes to the ASC Quality Reporting Program
Proposed requirements for the ASC Quality Reporting Program relate to the measures that were finalized for the CYs 2014, 2015 and 2016 payment determinations in the CY 2012 Outpatient Prospective Payment System/ASC Payment System final rule.
Specifically, CMS is proposing new administrative, data completeness and extraordinary circumstance waivers or extension request requirements, as well as a reconsideration process. ASCs that fail to report quality data or to comply with these requirements will face a 2.0 percentage point reduction in their annual payment update for that payment determination year, beginning in CY 2014. Data collection for the CY 2014 payment determination will begin with services furnished on Oct. 1.
Proposals for New Quality Reporting Programs
Under the healthcare reform law, CMS is required to create new quality reporting programs that will apply to 11 cancer hospitals and inpatient psychiatric exempt from payment under the Inpatient Prospective Payment System.
CMS has proposed that cancer hospitals report on an initial set of five quality measures beginning in FY 2013. The proposed measures include two healthcare-associated infection measures developed by the CDC — central line-associated bloodstream infections and catheter-associated urinary tract infections — along with three cancer "process of care" measures on chemotherapy and hormone therapy developed by the American College of Surgeons.
For inpatient psychiatric hospitals, CMS has proposed an initial set of six "process of care" quality measures for reporting, starting in FY 2013. The six proposed measures, developed by The Joint Commission, focus on administration of antipsychotic medications, use of restraints, hours of patient seclusion, creation of post-discharge continuing care plans and transmission of those plans to subsequent care providers after discharge. Inpatient psychiatric facilities that fail to comply with quality data submission requirements are subject to a payment reduction under this proposed program.
For more information on the proposed rule, measure set changes and associated payment structures, click here. CMS will accept comments on the proposal rule until June 25 and will issue a final rule by August 1.
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