Tuesday, 11 August 2015 03:36

CMS Releases More Final 2016 PPS Rules: Quality Continues to Be a Major Component

Written by

Below are some excerpts from the 2016 final rules related to value-based purchasing (VBP) and quality for inpatient psychiatric facilities (IPFs) and inpatient rehabilitation facilities (IRFs). We will be following up with additional articles over the next few weeks featuring industry reaction, so please stay tuned.

Background on the IPFQR Program: The IPFQR Program is a pay-for-reporting program established by the Patient Protection and Affordable Care Act (PPACA). IPFs are subject to a reduction of two percentage points in their annual payment update for failure to meet administrative and data reporting requirements on specified quality measures. The current IPFQR Program measure set includes 14 measures. In the final rule for the 2016 fiscal year, CMS is increasing the IPFQR Program measure set to 16 measures by adding five measures and removing three measures. CMS is also finalizing several policies that will lessen the burden on reporting entities.

Measures Adopted for the 2018 Payment Determination and Subsequent Years

  • One Tobacco Treatment Measure: TOB-3 - Tobacco Use Treatment Provided or Offered at Discharge, and a subset measure, TOB-3a Tobacco Use Treatment at Discharge (NQF No. 1656), measure patients 18 and older who have used tobacco products and who were referred to counseling and received or refused a prescription for cessation medication upon discharge. The subset measure includes only those patients who received counseling and cessation medication at discharge. IPFs will be required to begin collecting data for this measure on Jan. 1, 2016.
  • One Substance Use Treatment Measure: SUB-2 - Alcohol Use Brief Intervention Provided or Offered, and a subset measure, SUB-2a Alcohol Use Brief Intervention (NQF #1663), measure patients 18 and older to whom a brief substance-abuse intervention was provided, or offered and refused. The subset measure includes only those patients who received a brief intervention. IPFs will be required to begin collecting data for this measure on Jan. 1, 2016.
  • Two Transition Record Measures: Transition Record with Specified Elements Received by Discharged Patients (Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care) (NQF No. 0647) measures the percentage of patients discharged from an inpatient facility, or their caregivers, who received a transition record with specified elements at the time of discharge. For the 2018 payment determination, IPFs will be required to collect only two quarters of data, beginning on July 1, 2016. Beginning with the 2019 payment determination, IPFs will be required to report all four quarters of data.
  • Timely Transmission of Transition Record: Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care (NQF No. 0648) measures the percentage of patients discharged from an inpatient facility for whom a transition record was transmitted to the healthcare setting designated for follow-up care within 24 hours of discharge. For the 2018 payment determination, IPFs will be required to collect only two quarters of data, beginning on July 1, 2016. Beginning with the 2019 payment determination, IPFs will be required to report all four quarters of data.
  • One Screening for Metabolic Disorders Measure: Screening for Metabolic Disorders measures the percentage of patients discharged with an antipsychotic prescription for which a structured metabolic screening for: a) BMI; b) blood pressure; c) glucose or HbA1c; and d) lipid panel was completed in the past year. For the 2018 payment determination, IPFs will be required to collect only two quarters of data, beginning on July 1, 2016. Beginning with the 2019 payment determination, IPFs will be required to report all four quarters of data.

Measures Removed 

Beginning with 2017 Payment Determination: CMS removed HBIPS 4 (Patients Discharged on Multiple Antipsychotic Medications) due to the loss of NQF endorsement, and because CMS believes that HBIPS-5 Patients Discharged on Multiple Antipsychotic Medications with Appropriate Justification sufficiently includes the data that HBIPS-4 was intended to collect.

Beginning with 2018 Payment Determination: CMS removed HBIPS 6 (Post-Discharge Continuing Care Plan Created) and HBIPS 7 (Post-Discharge Continuing Care Plan Transmitted to Next Level of Care Provider Upon Discharge) because these measures would be superfluous to, and not as robust as, the two transition measures CMS adopted for 2018 and subsequent years.

Other Changes

CMS also made the following changes to the data reporting requirements for IPFQR Program measures:

  • Beginning with 2017 Payment Determination: CMS will require IPFs to report measure data as a single, yearly count rather than by quarter and age because obtaining data for each quarter and by age is burdensome to providers and the resultant number of cases is often too small to allow for public reporting. In addition, CMS will require IPFs to report aggregate population counts for discharges as a single, yearly count rather than by quarter.
  • Beginning with 2018 Payment Determination: CMS will give providers the option of obtaining one global sample for most measures, rather than having different sampling requirements for different measures. CMS believes that uniform sampling will decrease provider burden and allow for streamlined procedures.

The final IPF PPS rule can be downloaded from the Federal Register online at www.federalregister.gov/public-inspection. It was scheduled to be published in the Federal Register on August 5, 2015.

The Improving Medicare Post-Acute Care Transformation Act of 2014 (the “IMPACT” Act) added Section 1899B to the Social Security Act (the Act) to require that IRFs report data on measures that satisfy measure domains specified in the Act. These same measures are to be implemented in long-term care hospitals (LTCHs), IRFs, skilled nursing facilities and home health agencies. This final rule adopts measures that satisfy three of the quality domains required by the IMPACT Act in 2016: skin integrity and changes in skin integrity; functional status, cognitive function, and changes in function and cognitive function; and incidence of major falls. IRFs that fail to submit the required quality data to CMS will be subject to a two-percentage point reduction to their applicable annual increase factor.

Finalized Changes:

The domains specified by the IMPACT Act and the quality measures finalized are as follows:

  • Domain 1. Skin integrity and changes in skin integrity:
    • Quality Measure: “Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened”  (NQF No. 0678)
  • Domain 2. Functional status, cognitive function, and changes in function and cognitive function:
    • Quality Measure: Application of the “Percent of Long-Term Care Hospital Patients With an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function” (NQF No. 2631; Endorsed on July 23, 2015)
  • Domain 3. Incidence of major falls:
    • Quality Measure: Application of the “Percent of Residents Experiencing One or More Falls with Major Injury” (NQF No. 0674)

In addition to the measures listed above, we are adopting four additional functional status quality measures, as well as finalizing the previously finalized quality measure “All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from Inpatient Rehabilitation Facilities” (NQF No. 2502) in order to establish its newly NQF-endorsed status.

Further, we will begin publically reporting IRF quality data in fall 2016. Our policy for public reporting includes a 30-day period for review and correction of quality data prior to public display.

Finally, we are temporarily suspending our previously finalized data validation policy. CMS is suspending this policy in order to allow time to develop a more comprehensive policy that potentially decreases the burden on IRF providers, allows us to establish an estimation of accuracy related to quality data submitted to CMS, and facilitates the alignment of the IRF validation policy with that of other CMS quality reporting programs policies.

The final IRF PPS rule can be downloaded from the Federal Register online at: http://www.federalregister.gov/public-inspection. The rule will be effective October 01, 2015.

About the Author

Kim Charland is the Publisher of VBPmonitor and can be reached at This email address is being protected from spambots. You need JavaScript enabled to view it.

Contact the Author

This email address is being protected from spambots. You need JavaScript enabled to view it.

Comment on this Article

This email address is being protected from spambots. You need JavaScript enabled to view it.