August 31, 2022

In this final installment of our review of the 2023 Medicare Inpatient Prospective Payment System (IPPS) Final Rule (FR), we will be focusing on the various quality programs outlined in the rule.  The key quality provisions that will be deemed important to hospital decision-makers are provided in the following sections.

Inpatient Quality Reporting Program

The Hospital Inpatient Quality Reporting (IQR) Program is a pay-for-reporting quality program that reduces payment to hospitals that do not meet all IQR requirements, including the timely reporting of quality measure data.  The adjustment in such cases would amount to a one-fourth reduction in their Annual Payment Update under the IPPS.  The FR adopts the following measures:

• Hospital Commitment to Health Equity measure beginning with the CY 2023 reporting period/FY 2025 payment determination.
• Screening for Social Drivers of Health measure and Screen Positive Rate for Social Drivers of Health measure beginning with voluntary reporting in the CY 2023 reporting period and mandatory reporting beginning with the CY 2024 reporting period/FY 2026 payment determination.
• Two perinatal eCQMs—Cesarean Birth and Severe Obstetric Complications—available for self-selection beginning with the CY 2023 reporting period/FY 2025 payment determination followed by mandatory reporting beginning with the CY 2024 reporting period/FY 2026 payment determination.
• Hospital-Harm—Opioid-Related Adverse Events eCQM beginning with the CY 2024 reporting period/FY 2026 payment determination.
• The Global Malnutrition Composite Score eCQM beginning with the CY 2024 reporting period/FY 2026 payment determination.
• Hospital-Level Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) Patient-Reported Outcome performance measure beginning with two voluntary reporting periods (July 1, 2023 through June 30, 2024 and July 1, 2024 through June 30, 2025), followed by mandatory reporting for the reporting period which runs from July 1, 202 through June 30, 2026, impacting the FY 2028 payment determination.
• Hospital-Level Risk-Standardized Complication Rate Following Elective Primary THA/TKA measure beginning with the FY 2024 payment determination.
• Medicare Spending Per Beneficiary—Hospital measure beginning with the FY 2024 payment determination.

The Centers for Medicare and Medicaid Services (CMS) is also refining 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 measure and Excess Days in Acute Care After Hospitalization for Acute Myocardial Infarction measure.

Additionally, CMS is updating two policies related to eCQMs. First, the eCQM validation policy will 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.  Second, the eCQM reporting and submission requirements will 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.  CMS is also removing the zero denominator declarations and case threshold exemptions policies for hybrid measures beginning with the FY 2026 payment determination.

Lastly, CMS is establishing submission and reporting requirements for Patient-Reported Outcome measures beginning with the FY 2026 payment determination, specifically for the THA/TKA Patient-Reported Outcome measure being finalized in this FR, since this is a new measure type for the Hospital IQR Program.

Promoting Interoperability Program

In 2011, CMS established the Medicare and Medicaid EHR Incentive Programs [now known as the Promoting Interoperability Programs for eligible hospitals and critical access hospitals (CAHs)] to encourage eligible professionals, eligible hospitals, and CAHs to adopt, implement, upgrade, and demonstrate meaningful use of certified EHR technology (CEHRT).  With this rule, CMS is finalizing the following changes to the Medicare Promoting Interoperability Program for eligible facilities:

• Make mandatory the Electronic Prescribing Objective’s Query of Prescription Drug Monitoring Program (PDMP) measure, adding a third exclusion to the two that CMS proposed; expand the measure to include not only Schedule II opioids, but also Schedule 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 2024 EHR reporting period;
• Beginning with the CY 2023 EHR reporting period, 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, require submission of the level of active engagement, in addition to submitting the measures for the Public Health and Clinical Data Exchange Objective;
• Beginning with the CY 2024 EHR reporting period, require eligible hospitals and CAHs to limit the duration of their time on level of active engagement option one to a single EHR reporting period.
• 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, CMS will increase the Public Health and Clinical Data Exchange Objective from 10 to 25 points, increase the points associated with the Electronic Prescribing Objective from 10 to 20, reduce the points associated with the Health Information Exchange Objective from the current 40 points to 30 points, and 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 CY 2023 reporting period, and two new eCQMs beginning with the CY 2024 reporting period, in alignment with 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 the Hospital IQR Program.

Value-Based Purchasing Program

The Hospital Value-Based Purchasing (VBP) Program is a budget-neutral program funded by reducing participating hospitals’ base operating MS-DRG payments each fiscal year by two percent and redistributing the entire amount back to the hospitals as value-based incentive payments.  In this FR, CMS is pausing the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) and five Hospital Acquired Infection (HAI) measures, for the purposes of scoring and payment for the FY 2023 program year.  As a result of the above measure pauses for the FY 2023 program year, less than half of the Hospital VBP Program measures will be available for accurate scoring.  Therefore, CMS will also not calculate a Total Performance Score (TPS) for any hospital and instead award all hospitals a value-based payment amount for each discharge that is equal to the amount withheld. 

CMS will calculate measure rates for all measures and publicly report those rates where feasible and appropriately caveated.  CMS will also update the baseline periods for certain measures for the FY 2025 program year.  Lastly, the FR contains technical administrative updates to the measures included in the Clinical Outcomes Domain.

A full summary of the 2023 IPPS Final Rule can be found at FY 2023 Hospital Inpatient Prospective Payment System (IPPS) and Long Term Care Hospitals (LTCH PPS) Final Rule — CMS-1771-F Maternal Health | CMS.  For questions pertaining to our hospital-specific business services, please contact at info@miramedgs.com.