Regulatory Advisory
Regulatory Advisory 2016 Hospital Inpatient Prospective Payment System (IPPS) NPRM (CMS-1632-P) In the April 30, 2015 edition of the Federal Register (80 FR) the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule to revise the Medicare hospital inpatient prospective payment systems (IPPS) for operating and capital-related costs of acute care hospitals for FY 2016. In addition, CMS is proposing to establish new requirements for Medicare quality reporting programs, including the Inpatient Quality Reporting (IQR) program and related proposals for eligible hospitals (EHs) and critical access hospitals (CAHs) participating in the Medicare Electronic Health Record (EHR) Incentive Program. CMS proposes a number of changes to the Hospital IQR program, including a requisite set of 47 measures for the FY 2018 payment determination, and a required set of 16 out of 28 electronically specified measures. (This proposed mandatory reporting differs from the voluntary electronic reporting adopted for FY 2017 payment determination). Specifically, CMS is proposing that, beginning in CY 2016/FY 2018 payment determination and subsequent years, they will require hospitals to select and submit 16 electronic clinical quality measures (eCQMs) covering three National Quality Strategy (NQS) domains from a list of 28 available eCQMs (see Table 1). For the FY 2018 payment determination, hospitals would be required to submit Q3 and Q4 CY 2016 data for 16 measures of their choice. This proposal is in alignment with the Medicare EHR Incentive Program, as discussed in section VIII.D.2.b. of the NPRM, which states hospitals participating in Meaningful Use have the option of submitting 16 eCQMs in Q3 and Q4 of CY 2016 or submitting CQM data via Registration and Attestation website. For hospitals and CAHs participating in both IQR and MU, and are reporting CQMs electronically, CMS proposes that for 2016, two full quarters of data (Q3 and Q4 of CY 2016) be submitted within two months after the end of the quarter (i.e., November 30, 2016 for Q3 and February 28, 2017 for Q4). For eligible hospitals and CAHs reporting CQMs by attestation, reporting for CY 2016 would be required by February 28, 2017. However for those demonstrating meaningful use for the first time in 2016, attestation could alternatively be made for any continuous 90-day reporting period within 2016. 1 College of Healthcare Information Management Executives 20 F Street NW, Suite 700 · Washington, DC 20001 Phone: (202) 507-6158 · Fax: (734) 665-4922 · [email protected] · www.chimecentral.org CMS says they will “delay publicly reporting electronic clinical quality measure data submitted by hospitals for CY 2016/FY 2018 payment determination in order to allow time to evaluate the effectiveness of electronically reported clinical quality measure data.” In the meantime, measures reported via eCQM will be marked with a footnote on Hospital Compare noting that: (1) the hospital submitted data via EHR; (2) data is being processed and analyzed; and (3) CMS will eventually publicly report this data once CMS determines the data to be reliable and accurate. If finalized as proposed, the policy requiring hospitals to submit eCQMs for IQR will be more stringent than the requirements for MU, as hospitals can still report CQMs through attestation under MU rules.. This is the first time CMS is proposing to require submission of electronic CQMs, foreshadowing rule makers’ intention to further cement the use of IT in quality measurement. The 60-day comment period for the proposed rule will end on June 15, 2015. A final rule will be published around July 31, 2015, with the rates and policy changes generally taking effect on October 1, 2015. Questions & Comments should be directed to: Leslie Krigstein Interim Vice President of Public Policy [email protected] (202) 507-6158 (May 2015) 2 College of Healthcare Information Management Executives 20 F Street NW, Suite 700 · Washington, DC 20001 Phone: (202) 507-6158 · Fax: (734) 665-4922 · [email protected] · www.chimecentral.org Table 1: Listing of Potential IQR / MU Electronic CQMs for Hospitals in CY 2016 Hospital IQR Program Measures for the FY 2018 Payment Determination and Subsequent Years Short Name Measure Name NQF # Electronic Clinical Quality Measure AMI-2a Aspirin Prescribed at Discharge for AMI 142 AMI-7a Fibrinolytic Therapy Received Within 30 Minutes of Hospital Arrival 164 AMI-8a AMI-10 Primary PCI Received Within 90 Minutes of Hospital Arrival Statin Prescribed at Discharge Home Management Plan of Care Document Given to Patient/Caregiver 163 N/A CAC-3 N/A ED-1 Median Time from ED Arrival to ED Departure for Admitted ED Patients 495 ED-2 Admit Decision Time to ED Departure Time for Admitted Patients 497 Hearing Screening Prior to Hospital Discharge Healthy Term Newborn Elective Delivery (Collected in aggregate, submitted via Web-based tool or electronic clinical quality measure) 1354 716 EHDI-1a HTN PC-01 469 PC-05 Elective Delivery (Collected in aggregate, submitted via Web-based tool or electronic clinical quality measure) 480 PN-6 Initial Antibiotic Selection for Community-Acquired Pneumonia (CAP) in Immunocompetent Patients 147 SCIP-Inf-1a SCIP-Inf-2a SCIP-Inf-9 STK-02 STK-03 STK-04 STK-05 STK-06 STK-08 Prophylactic Antibiotic Received Within One Hour Prior to Surgical Incision Prophylactic Antibiotic Selection for Surgical Patients 527 528 Urinary catheter Removed on Postoperative Day 1 (POD 1) or Postoperative Day 2 (POD 2) with Day of Surgery Being Day Zero N/A Discharged on Antithrombotic Therapy Anticoagulation Therapy for Atrial Fibrillation/Flutter Thrombolytic Therapy Antithrombotic Therapy by the End of Hospital Day Two Discharged on Statin Medication Stroke Education 435 436 437 438 439 N/A 3 College of Healthcare Information Management Executives 20 F Street NW, Suite 700 · Washington, DC 20001 Phone: (202) 507-6158 · Fax: (734) 665-4922 · [email protected] · www.chimecentral.org STK-10 VTE-1 VTE-2 VTE-4 Assessed for Rehabilitation Venous Thromboembolism Prophy Intensive Care Unit Venous Thromboembolism Prophylaxis Venous Thromboembolism Patients with Anticoagulation Overlap Therapy Venous Thromboembolism Discharge Instructions N/A VTE-5 Incidence of Potentially Preventable Venous Thromboembolism N/A VTE-6 Incidence of Potentially Preventable Venous Thromboembolism N/A VTE-3 441 371 372 373 4 College of Healthcare Information Management Executives 20 F Street NW, Suite 700 · Washington, DC 20001 Phone: (202) 507-6158 · Fax: (734) 665-4922 · [email protected] · www.chimecentral.org
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