Tuesday, 13 September 2016 04:08

2017 Hospital and Ambulatory Surgery OPPS Quality Proposed Rule

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The Centers for Medicare and Medicaid (CMS) released the 2017 OPPS Rule on July 6, 2016 and accepted comments up until Tuesday, September 6, 2016.  Now CMS has the task of reading and responding to all of the comments received in the final rule that is expected out sometime in November.

Below is the CMS News Release from July 6th, 2016:  

Hospital Value-Based Purchasing (VBP) Program

The Hospital VBP Program, funded by a 2 percent reduction from participating hospitals’ base operating diagnosis-related group (DRG) payments each year, requires CMS to redistribute a portion of the Medicare payments to hospitals for inpatient services based on performance.  In this CY 2017 OPPS/ASC proposed rule, CMS is proposing to remove the Pain Management dimension of the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) survey for purposes of the Hospital VBP Program, beginning with the FY 2018 program year.  Other Hospital VBP Program requirements will be set forth in an upcoming FY 2017 IPPS/LTCH PPS final rule to be issued on or around August 1, 2016.

CMS has received feedback that some stakeholders are concerned about the pain management dimension questions being used in the Hospital VBP Program, believing that the linkage of these particular questions to the Hospital VBP Program payment incentives creates pressure on hospital staff to prescribe more opioids in order to achieve higher scores on this dimension.  The pain management dimension questions do not specify any particular type of pain control method.  In addition, appropriate pain management includes communication with patients about pain-related issues, setting expectations about pain, shared decision-making, and proper prescription practices.  Although CMS is not aware of any scientific studies that support an association between scores on the pain management dimension questions and opioid prescribing practices, we are proposing to remove the pain management dimension of the HCAHPS survey for purposes of the Hospital VBP Program in an abundance of caution. We are also developing and field testing alternative questions related to provider communications and pain in order to remove any potential ambiguity in the HCAHPS survey.

While CMS is developing alternative pain management questions, HCAHPS survey data on all dimensions of care, including pain management, will continue to be publicly reported under the Hospital Inpatient Quality Reporting (IQR) Program in recognition that pain control is an important aspect to delivering quality care.  We believe this approach would appropriately balance concerns that clinicians could face financial pressure to prescribe opioids without compromising the only source of nationally comparable data on pain management and pain management disparities.

Hospital Outpatient Quality Reporting (OQR) Program: Proposed Changes for CY 2018, 2019, and 2020 Payment Determinations and Subsequent Years

The Hospital OQR Program is a pay for quality data reporting program for outpatient hospital services. The Hospital OQR Program requires hospital outpatient facilities to meet administrative, data collection, and submission, validation, and reporting requirements, or receive a reduction of 2.0 percentage points in their annual payment update for failure to meet these requirements.

In the CY 2017 OPPS/ASC Proposed Rule, CMS is proposing to add a total of seven measures to the Hospital OQR Program for the CY 2020 payment determination and subsequent years: Two claims-based measures, and five Outpatient and Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS) survey-based measures. The seven measures are:

  • OP-35: Admissions and Emergency Department Visits for Patients Receiving Outpatient Chemotherapy, which assesses the care provided to cancer patients and encourages quality improvement efforts to reduce the number of unplanned inpatient admissions and emergency department (ED) visits among cancer patients receiving chemotherapy in a hospital outpatient setting.
  • OP-36: Hospital Visits after Hospital Outpatient Surgery (NQF #2687), which assesses variations in patient outcomes following surgery at a hospital outpatient department (HOPD). 
  • OP-37(a-e):  Five proposed measures that are collected using the Outpatient and Ambulatory Surgical Center Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS) survey, a patient experience of care survey which assesses patients’ access to care, interactions with facility staff, and overall experience at the facility.

CMS is seeking public comment on a future electronic clinical quality measure concept for the Hospital OQR Program that addresses concerns associated with overlapping or concurrent prescribing of opioids or opioids and benzodiazepines. This measure concept is designed to reduce preventable deaths as well as reduce costs associated with the treatment of opioid-related ED use by encouraging providers to identify patients at high risk for overdose due to respiratory depression or other adverse drug events.

We note that CMS is not proposing any changes to the CY 2018 and CY 2019 Hospital OQR Program measure sets, which include 26 measures—25 required and one voluntary.

Additionally, beginning with the CY 2018 payment determination, CMS is proposing to publicly display data on the Hospital Compare Web site, or other CMS Web site, as soon as possible after measure data have been submitted to CMS.  In addition, the agency is proposing that hospitals will generally have approximately 30 days to preview their data.  CMS is also proposing to announce the timeframes for the preview period on a CMS Web site and/or on its applicable listservs.  Furthermore, beginning with the CY 2019 payment determination, CMS proposes to update the Extraordinary Circumstances Exemptions (ECE) policy by changing the ECE request deadline from 45 days from the date that the extraordinary circumstance occurred to 90 days from the date that the extraordinary circumstance occurred.

Ambulatory Surgical Center Quality Reporting (ASCQR) Program 

The ASCQR Program is a pay-for-reporting program that requires ambulatory surgical centers (ASCs) to meet administrative, data collection, and reporting requirements, or receive a reduction of 2.0 percentage points in their annual payment update for failure to meet the requirements.

In the CY 2017 OPPS/ASC proposed rule, CMS is proposing to add seven measures to the ASCQR program measure set for the CY 2020 payment determination and subsequent years.  The seven measures are:

  • ASC-13: Normothermia Outcome, which assesses the percentage of patients having surgical procedures under general or neuraxial anesthesia of 60 minutes or more in duration who are normothermic within 15 minutes of arrival in the post-anesthesia care unit (PACU).
  • ASC-14: Unplanned Anterior Vitrectomy, which assesses the percentage of cataract surgery patients who have an unplanned anterior vitrectomy (removal of the vitreous present in the anterior chamber of the eye).
  • ASC-15(a-e): Five proposed measures that are collected using the Outpatient and Ambulatory Surgical Center Consumer Assessment of Healthcare Providers and Systems (OAS CAHPS) survey, a patient experience of care survey which assesses patients’ access to care, interactions with facility staff, and overall experience at the facility.

CMS is seeking public comment on a quality measure for future consideration in the ASCQR Program that addresses Toxic Anterior Segment Syndrome (TASS), a complication of anterior segment eye surgery.  This measure assesses the number of ophthalmic anterior segment surgery patients diagnosed with TASS within two days of surgery.

We note that CMS is not proposing any changes to the CY 2018 and CY 2019 ASCQR Program measure sets, which include 12 measures—11 required and one voluntary.

Additionally, beginning with the CY 2018 payment determination, CMS is proposing to publicly display data on the Hospital Compare Web site, or other CMS Web site, as soon as possible after measure data have been submitted to CMS.  In addition, the agency is proposing that hospitals will generally have approximately 30 days to preview their data.  CMS is also proposing to announce the timeframes for the preview period on a CMS Web site and/or on its applicable listservs.  CMS is further proposing, beginning with the CY 2019 payment determination, to update the Extraordinary Circumstances Exemptions (ECE) policy by extending the ECE request deadline from within 45 days of the date that the extraordinary circumstance occurred to within 90 days of the date that the extraordinary circumstance occurred.  CMS is also proposing to implement a May 15 submission deadline for all data submitted via a CMS Web-based tool in the ASCQR Program beginning with the CY 2019 payment determination.

The proposed rule will appear in the July 14, 2016, Federal Register and can be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection.

VBPmonitor will be covering more on this once the final rule is released.

About the Author

Kim Charland is the editor of VBPmonitor and the senior vice president of clinical innovation with Panacea Healthcare Solutions. Kim has 30 years of experience in health information and reimbursement management for hospitals and physician offices. Kim’s primary role with Panacea is publisher of VBPmonitor.com, which is the company’s newest online monitor and is focused on value-based purchasing and quality. She is also co-host of ICD10monitor.com’s Internet news broadcast Talk-Ten-Tuesdays. In addition, she assists with product development for Panacea’s consulting and software divisions, as well as the MedLearn publishing division. Kim is also recognized as a national speaker who has spoken for numerous organizations.

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Last modified on Wednesday, 14 September 2016 04:15