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