May 4, 2022

In last week’s alert, we provided some of the key highlights found in the federal government’s Hospital Inpatient Prospective Payment Systems (IPPS) Proposed Rule (PR) for fiscal year (FY) 2023 (beginning October 1, 2022).  Today’s alert will flesh out some of the proposed changes in hospital-related quality programs found in that same PR.

Quality-Reporting Program

The Hospital Inpatient Quality-Reporting (IQR) Program is a pay-for-reporting quality program that reduces payment to those hospitals failing to meet the specified program requirements. The Centers for Medicare and Medicaid Services (CMS) is proposing in this PR that hospitals that fail to submit quality data or fail to meet all of the IQR Program requirements will be subject to a one-fourth reduction in their Annual Payment Update (APU) under IPPS. 

Under the PR, CMS is proposing to adopt the following measures:

• Hospital Commitment to Health Equity measure.
• Screening for Social Drivers of Health measure and Screen Positive Rate for Social Drivers of Health.
• Two perinatal eCQMs—Cesarean Birth and Severe Obstetric Complications.
• Hospital-Harm—Opioid-Related Adverse Events eCQM (NQF #3501e).
• The Global Malnutrition Composite Score eCQM (NQF #3592e).
• Hospital-Level Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) PRO-PM (NQF #3559).
• Hospital-Level Risk-Standardized Complication Rate (RSCR) Following Elective Primary THA/TKA measure (NQF #1550).
• Medicare Spending Per Beneficiary—Hospital measure (NQF #2158).

CMS is also proposing refinements to two measures that are currently part of the Hospital IQR Program measure set beginning with the FY 2024 payment determination: Hospital‐Level, Risk‐Standardized Payment Associated with an Episode-of-Care for Primary Elective THA and/or TKA (NQF #3474) and Excess Days in Acute Care (EDAC) After Hospitalization for Acute Myocardial Infarction (AMI) (NQF #2881).

Additionally, CMS is proposing two measure modifications:

• Modify the eCQM validation policy to increase the submission requirement from 75 percent to 100 percent of the requested medical records to successfully complete eCQM validation beginning with the FY 2025 payment determination.
• Modify the eCQM reporting and submission requirements to increase eCQM reporting from four eCQMs (one mandatory and three self-selected) to six eCQMs (three mandatory and three self-selected) beginning with the CY 2024 reporting period/FY 2026 payment determination.

Promoting Interoperability

CMS is proposing the following changes to the Medicare Promoting Interoperability Program:

• Make mandatory the Electronic Prescribing Objective’s Query of Prescription Drug Monitoring Program (PDMP) measure, expand to include Schedule II, III, and IV drugs and maintain the associated points at 10 points;
• Add a new Enabling Exchange under the Trusted Exchange Framework and Common Agreement (TEFCA) measure under the Health Information Exchange (HIE) Objective as a yes/no attestation measure, beginning with the EHR reporting period in CY 2023, as an optional alternative to the three existing measures under the HIE Objective;
• Add a new Antimicrobial Use and Resistance (AUR) Surveillance measure and require its reporting under the Public Health and Clinical Data Exchange Objective, beginning with the CY 2023 EHR reporting period;
• Beginning with the CY 2023 EHR reporting period, we are proposing to reduce the active engagement options for the Public Health and Clinical Data Exchange Objective from three to two options;
• Beginning with the CY 2023 EHR reporting period, we are proposing to require submission of the level of active engagement, in addition to submitting the measures for the Public Health and Clinical Data Exchange Objective;
• Institute public reporting of certain Medicare Promoting Interoperability Program data beginning with the CY 2023 EHR reporting period;
• Beginning with CY 2023 EHR reporting period, we are proposing to increase the Public Health and Clinical Data Exchange Objective from 10 to 25 points, to increase the points associated with the Electronic Prescribing Objective from 10 to 20, to reduce the points associated with the Health Information Exchange Objective from the current 40 points to 30 points, and to reduce the points associated with the Provide Patients Electronic Access to Their Health Information from the current 40 to 25 points;
• Adopt two new eCQMs to the Medicare Promoting Interoperability Program’s eCQM measure set beginning with the reporting period in CY 2023, and two new eCQMs beginning with the reporting period in CY 2024 in alignment with proposals for the Hospital IQR Program;
• Modify the eCQM reporting and submission requirements to increase eCQM reporting from four eCQMs (one mandatory and three self-selected) to six eCQMs (three mandatory and three self-selected) beginning with the CY 2024 reporting period in alignment with proposals in the Hospital IQR Program.

Hospital-Acquired Condition Reduction Program

The Hospital-Acquired Condition (HAC) Reduction Program creates an incentive for hospitals to reduce the incidence of hospital-acquired conditions by requiring the Secretary to reduce payment by 1 percent for applicable hospitals that rank in the worst performing quartile on select measures of hospital-acquired conditions.  Among the proposals are the following:

• Suppress the CMS PSI 90 measure and the five CDC NHSN HAI measures from the calculation of measure scores and the Total HAC Score, thereby not penalizing any hospital under the HAC Reduction Program FY 2023 program year;
• Publicly and confidentially (through Hospital Specific Report) report CDC NHSN HAI measure results but not calculate or report measure results for the CMS PSI 90 measure for the HAC Reduction Program FY 2023 program year due to misaligned data periods;
• Suppress CY 2021 CDC NHSN HAI measures data from the FY 2024 HAC Reduction Program Year;

Value-Based Purchasing Program

The Hospital Value-Based Purchasing (VBP) Program is a budget-neutral program funded by reducing participating hospitals’ base operating DRG payments each fiscal year by 2 percent and redistributing the entire amount back to the hospitals as value-based incentive payments. In this PR, CMS is proposing to suppress the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) and five Hospital Acquired Infection (HAI) measures.

As a result of the above, less than half of the Hospital VBP Program measures would be available for accurate national comparison. Therefore, CMS is also proposing to not calculate a TPS for any hospital and to instead award all hospitals a value-based payment amount for each discharge that is equal to the amount withheld.

————–

Only time will tell which of the FY 2023 IPPS proposals will go on to be adopted.  We will bring you the 2023 IPPS Final Rule once those provisions are released later this year.  Until then, if you have questions for us, please go to the following link: info@miramedgs.com.