Kim Charland, BA, RHIT, CCS

Approximately 1,600 hospitals out of 3,000 will receive Medicare bonuses in 2017, leaving about 1,300 hospitals receiving a negative payment adjustment. The Centers for Medicare & Medicaid Services (CMS) released the news on Tuesday, Nov. 1, 2016. 

In addition, for the 2017 fiscal year, about half of hospitals will see a small change in their base operating MS-DRG payments (between -0.5 and plus-0.5 percent). After taking into account the statutorily mandated 2-percent withholding, the highest-performing hospitals will receive a net increase in payments of slightly more than 4 percent, and the lowest-performing hospitals will incur a net reduction of 1.83 percent.

The domains for the 2017 fiscal year Hospital Value-Based Purchasing (VBP) Program and the weighting for these domains were:

  • Clinical Care (30 percent)
    • Outcomes (25 percent)
    • Process (5 percent)
  • Patient and Caregiver-Centered Experience of Care/Care Coordination (25 percent)
  • Safety (20 percent)
  • Efficiency and Cost Reduction (25 percent)

According to a Nov. 1 article in Modern Healthcare, “the results are ‘somewhat concerning,’” said Francois de Brantes, executive director of the Health Care Incentives Improvement Institute. One reason was the fact that fewer hospitals are being rewarded. Another was hospitals' lack of movement in rankings.

The number of hospitals whose payments were docked grew from 1,236 in 2016 to 1,343 in 2017, according to a Modern Healthcare analysis of the data. Last year, 59 percent of hospitals received bonus payments; this year, 55 percent did.

More than half of the 2,879 hospitals participating in the program both years will see lower payment adjustments in 2017 than in 2016. Payments improved for 1,388 of those hospitals.

About 1,250 hospitals earned bonuses both years, and 875 were hit with penalties both years. By comparison, 437 hospitals that earned bonuses last year were docked in 2017, and 315 hospital penalized in the last round will receive bonuses next year.

The measure set for the 2018 program year includes several changes:

  • Two measures from the clinical care/process sub-domain are being removed:  AMI-7a and IMM-2 measures. The remaining measure, PC-01, is moving to the Safety domain.
  • A three-item care transition dimension is being added, as part of the Hospital Consumer Assessment of Hospital Providers and Systems (HCAHPS) survey, to the Patient and Caregiver Centered Experience of Care/Care Coordination domain.
  • In the 2017 Outpatient Prospective Payment System (OPPS) final rule, the pain management dimension – which is derived from the HCAHPS survey – is being removed from the Patient and Caregiver-Centered Experience of Care/Care Coordination domain, beginning with the 2018 fiscal year VBP program.

The 2018 Hospital VBP Program will include four equally weighted domains:

  • Clinical Care (25 percent)
  • Patient Experience and Caregiver-Centered Experience/Care Coordination (25 percent)
  • Safety (25 percent)
  • Efficiency and Cost Reduction (25 percent)

It is evident that the healthcare industry is moving forward at a rapid rate to implement programs focused on improving the quality of patient care and outcomes while reducing costs. While everyone may not agree on how it is being accomplished, I believe that everyone agrees that it is the right thing to do. The key will be to continue to assess what we are doing and improve on it moving forward.

CMS has posted the Hospital VBP incentive payment adjustment factors for the 2017 fiscal year in Table 16B, available online

For more information on the Hospital VBP Program, please visit the CMS website  and the QualityNet website

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.  Kim is also the president-elect for the New York Health Information Management Association. 

Contact the Author

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

On Tuesday, Nov. 1, 2016, the Centers for Medicare and Medicaid Services (CMS) released the final 2017 Outpatient Perspective Payment System (OPPS) rule. CMS stated in its fact sheet that “these finalized policy changes will improve the quality of care Medicare patients receive by better supporting their physicians and other healthcare providers and (reflecting) a broader Administration-wide strategy to create a healthcare system that results in better care, smarter spending, and healthier people.”

CMS will be removing from the 2017 patient satisfaction survey questions on pain management. CMS has said that it is not aware of any research to support an association between the patient satisfaction survey questions on pain management and the national opioid epidemic; however, due to multiple government agencies attempting to address this epidemic, the questions will be removed and alternate questions developed for future use.

CMS is adding seven measures to the Hospital Outpatient Quality Reporting Program for the 2020 payment determination and subsequent years.

Two are claims-based measures:

  • OP-35:  Admissions and Emergency Department Visits for Patients Receiving Outpatient Chemotherapy
  • OP-36: Hospital Visits after Hospital Outpatient Surgery

Five are Outpatient and Ambulatory Surgery Consumer Assessment of Healthcare Providers and Systems (OASCAHPS) Survey-based measures:

  • OP-37a: OASCAHPS - Facilities and Staff
  • OP-37b: OAS CAHPS - Communication about Procedure
  • OP-37c: OAS CAHPS - Preparation for Discharge and Recovery
  • OP-37d: OAS CAHPS - Overall Rating of Facility
  • OP-37e: OAS CAHPS - Recommendation of Facility

CMS is also making changes under the Medicare Electronic Health Record (EHR) Incentive Program for eligible hospitals and critical access hospitals attesting to CMS, including hospitals that are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs (dual-eligible hospitals), by eliminating the clinical decision support (CDS) and computerized order entry (CPOE) objectives and measures, beginning in 2017. CMS is reducing a subset of thresholds for the remaining objectives and measures for modified Stage 2 and Stage 3. Additional changes include allowing all returning participants in the EHR incentive programs to report on a 90-day EHR reporting period in 2016 and 2017. CMS is also finalizing an application process for a one-time, 2017 significant hardship exception to the Medicare EHR Incentive Program for certain eligible professionals who are also transitioning to the Merit-Based Incentive Payment System (MIPS). These additions increase flexibility, lower the reporting burden for providers, and focus on the exchange of health information and using technology to support patient care.

The OPPS /ASC Final Rule and IFC are available in the Federal Register, and accessible online.

A fact sheet on this final rule and IFC is available online.

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.  Kim is also the president-elect for the New York Health Information Management Association.

Contact the Author

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

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.

Contact the Author

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

Friday, 09 September 2016 06:55

CMS Releases MACRA Menu for Physicians

The Centers for Medicare and Medicaid released the following today:

September 8, 2016
By Andy Slavitt, Acting Administrator of CMS

“Plans for the Quality Payment Program in 2017: Pick Your Pace"

As the baby boom generation ages, 10,000 people enter the Medicare program each day. Facing that demand, it is essential that Medicare continues to support physicians in delivering high-quality patient care. This includes increasing its focus on patient outcomes and reducing the obstacles that make it harder for physicians to practice good care.

The bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) offers the opportunity to advance these goals and put Medicare on surer footing. Among other policies, it repeals the Sustainable Growth Rate formula and its annual payment cliffs, streamlines the existing patchwork of Medicare reporting programs, and provides opportunities for physicians and other clinicians to earn more by focusing on quality patient care. We are referring to these provisions of MACRA collectively as the Quality Payment Program.

We received feedback on http://www.hhs.gov/about/news/2016/04/27/administration-takes-first-step-implement-legislation-modernizing-how-medicare-pays-physicians.html">our April proposal for implementing the Quality Payment Program, both in writing and as we talked to thousands of physicians and other clinicians across the country. Universally, the clinician community wants a system that begins and ends with what's right for the patient. We heard from physicians and other clinicians on how technology can help with patient care and how excessive reporting can distract from patient care; how new programs like medical homes can be encouraged; and the unique issues facing small and rural non-hospital-based physicians. We will address these areas and the many other comments we received when we release the final rule by November 1, 2016.

But, with the Quality Payment Program set to begin on January 1, 2017, we wanted to share our plans for the timing of reporting for the first year of the program. In recognition of the wide diversity of physician practices, we intend for the Quality Payment Program to allow physicians to pick their pace of participation for the first performance period that begins January 1, 2017. During 2017, eligible physicians and other clinicians will have multiple options for participation. Choosing one of these options would ensure you do not receive a negative payment adjustment in 2019. These options and other supporting details will be described fully in the final rule.

First Option: Test the Quality Payment Program.

With this option, as long as you submit some data to the Quality Payment Program, including data from after January 1, 2017, you will avoid a negative payment adjustment. This first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019 as you learn more.

Second Option: Participate for part of the calendar year.

You may choose to submit Quality Payment Program information for a reduced number of days. This means your first performance period could begin later than January 1, 2017 and your practice could still qualify for a small positive payment adjustment. For example, if you submit information for part of the calendar year for quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a small positive payment adjustment. You could select from the list of quality measures and improvement activities available under the Quality Payment Program.

Third Option: Participate for the full calendar year.

For practices that are ready to go on January 1, 2017, you may choose to submit Quality Payment Program information for a full calendar year. This means your first performance period would begin on January 1, 2017. For example, if you submit information for the entire year on quality measures, how your practice uses technology, and what improvement activities your practice is undertaking, you could qualify for a modest positive payment adjustment. We've seen physician practices of all sizes successfully submit a full year’s quality data, and expect many will be ready to do so.

Fourth Option: Participate in an Advanced Alternative Payment Model in 2017.

Instead of reporting quality data and other information, the law allows you to participate in the Quality Payment Program by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. If you receive enough of your Medicare payments or see enough of your Medicare patients through the Advanced Alternative Payment Model in 2017, then you would qualify for a 5 percent incentive payment in 2019.

However, you choose to participate in 2017, we will have resources available to assist you and walk you through what needs to be done. And however you choose to participate, your feedback will be invaluable to building this program for the long term to achieve outcomes that matter to your patients.

We appreciate the sincere and constructive participation in the feedback process to date and look forward to advancing step-by-step in that same spirit. We look forward to releasing the final details about the program this fall. Most importantly, we look forward to further engagement with physicians and other clinicians toward our shared goal of the highest quality of care and best outcomes for patients.

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

Reference

CMS BLOG

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.

Contact the Author

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

Lately I feel as though time is passing by faster than ever – after all, my father always said the older you get, the faster it goes. I believe this is how most of us feel about the healthcare industry right now as well. We are facing changes that are forcing us to look outside the box and get out of our comfort zones. While I believe that we all have the patient’s best interests at heart, we have been functioning in silos – and this is no way to coordinate and impact patient care.

“Care coordination” is a phrase we have been seeing a lot of lately, but what does it really mean? The past several weeks have been crazy in healthcare, with the Centers for Medicare & Medicaid Services (CMS) releasing several policy and payment updates, including:

As I began to read and decipher these updates, it became clear to me that the underlying message is that we must do more with less. Not that I didn’t know this already, as we have been struggling with it for years. But now we must actually begin to report the improvement in care that our patients have been seeing, and we must also show that patients are satisfied, all while reducing costs.

I am grateful for the opportunities I have had recently to attend some very dynamic conferences: the LTPACHIT (Long-Term Post-Acute Care Health IT Summit), the National Association for Healthcare Quality (NAHQ) National Quality Summit, the Agency for Healthcare Research and Quality (AHRQ) Research Conference, the Association of Clinical Documentation Improvement Specialists (ACDIS) Annual Conference, the Healthcare Compliance Association (HCCA) annual conference, the New York Information Management Association (NYHIMA) annual conference, the Radiology Business Management Association (RBMA) Spring Summit, and the American Health Information Management Association (AHIMA) Leadership Conference. Speakers at all of these conferences were passionate in their messages regarding the move to payment for quality and working together (care coordination) to illustrate improving patient outcomes and to ensure financial survival. There is a reality check involved with admitting that we need to be financially successful; otherwise there will not be anyone to provide care to patients who need it.

So my point today is that in my opinion, care coordination is the key to making us all successful. We have to break down walls and begin talking to each other. We have to begin to trust each other. We need to think out of the box.

Much of our focus has been on the inpatient side of care and physician services, but much of the key to successfully managing patients is the care that happens on the post-acute side of care – rehabilitation, skilled nursing, long-term care, assisted living, home health, and hospice. These areas have traditionally taken a back seat to some degree, but it is extremely important that we reach out to them and include them in our discussions and decisions on how we are going to manage all of this. Without them, we will not be successful.

Below are a few items that I think should be on everyone’s population health management to-do list to analyze and establish a plan:

  • Communication – internal and external, with partners and with patients
  • Technology – to help us work smarter and more efficiently
  • Patient care – ensuring we provide care in the right setting and at the right time, being as proactive as we can
  • Data analytics – using our data to improve by identifying high-risk patients with multiple chronic conditions and high costs, as well to identify quality areas we need to focus improvement on
  • Quality data collection and reporting processes – these activities can be scattered within organizations, so we need to ensure continuity in both
  • Payor contract negotiations – as we move into more shared saving s models and APMs (alternative payment models), we need to ensure that we are negotiating smart contracts
  • Pricing and purchasing – to control and reduce costs where we can and reflect accurate costs per beneficiary
  • Leveraging community-based services – to manage patients in the right setting for both quality of care and cost control
  • Physician engagement – we are approaching a physician shortage, so it is important that we engage and support them
  • Patient engagement – we must engage patients to assist them in wanting to participate in their care to be compliant with treatment and care

VBPmonitor will be focusing on bringing you real-life experiences, case studies and best practices from hospitals and health systems, eligible clinicians, accountable care organizations (ACOs), health plans, payors, associations, and more to assist you in your transformation to true population health management.

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.

Contact the Author

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

Wednesday, 03 August 2016 00:29

Final 2017 IPPS Rule Released

The Centers for Medicare & Medicaid Services (CMS) yesterday released the final rule to update the fiscal year (FY) 2017 Medicare payment policies and rates under the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS). The final rule will impact discharges occurring on or after October 1, 2016 and continues to focus on the move from paying for volume of services to paying for increased quality of care and patient satisfaction while reducing costs.

VBPmonitor be covering in more detail how this will actually impact hospitals once we have a chance to read the entire rule, but we wanted to at least get CMS’s fact sheet out:

Changes and Updates in FY 2017 Policies

Changes to Payment Rates under IPPSThe final increase in operating payment rates for general acute care hospitals paid under the IPPS that successfully participate in the Hospital Inpatient Quality Reporting (IQR) Program and are meaningful electronic health record (EHR) users is approximately 0.95 percent. This reflects the projected hospital market basket update of 2.7 percent adjusted by -0.3 percentage point for multi-factor productivity and an additional adjustment of -0.75 percentage point in accordance with the Affordable Care Act. This also reflects a 1.5 percentage point reduction for documentation and coding required by the American Taxpayer Relief Act of 2012 and an increase of approximately 0.8 percentage points to remove the adjustment to offset the estimated costs of the Two Midnight policy and address its effects in FYs 2014, 2015, and 2016.

Hospitals that do not successfully participate in the Hospital IQR Program and do not submit the required quality data will be subject to a one-fourth reduction of the market basket update. Also, the law requires that any hospital that is not a meaningful EHR user will be subject to a three-fourths reduction of the market basket update in FY 2017.

CMS projects that the rate increase, together with other final changes to IPPS payment policies, will increase IPPS operating payments by approximately 1.0 percent and that changes in uncompensated care payments will decrease IPPS operating payments by 0.4 percent.  Other continued additional payment adjustments will include: a 1.0 percent reduction for hospitals in the lowest performing quartile under the Hospital Acquired Condition Reduction Program; payment adjustments for excess readmissions under the Hospital Readmissions Reduction Program; and incentive payments and reductions under the Hospital-Value Based Purchasing Program.  In sum, CMS projects that total Medicare spending on inpatient hospital services, including capital, will increase by about $746 million in FY 2017.

This projected increase in spending includes an estimated $350,000 increase in FY 2017 payments to hospitals located in Puerto Rico under the final policy to make IPPS payments for capital-related costs based solely on the national capital Federal rate (rather than the current blend of the national capital Federal rate and Puerto Rico-specific capital rate), consistent with the recent statutory change in the payment methodology for operating IPPS payments to those hospitals.

IPPS Rate Adjustments for Documentation and Coding and Two Midnight Policy
In the FY 2017 IPPS final rule, CMS is finalizing two adjustments in addition to its annual rate update for inpatient hospital payments. 

First, CMS is finalizing the last year of recoupment adjustments required by the American Taxpayer Relief Act of 2012 (ATRA). Section 631 of ATRA requires CMS to recover $11 billion by FY 2017 to fully recoup documentation and coding overpayments related to the transition to the MS-DRGs that began in FY 2008. For FYs 2014, 2015, and 2016, CMS implemented a series of cumulative -0.8 percent adjustments.  For FY 2017, CMS calculates that $5.05 billion of the $11 billion requirement remains to be addressed.  Therefore, CMS is finalizing a -1.5 percent adjustment to complete the statutorily-specified recoupment. 

Second, CMS is taking action regarding the -0.2 percent adjustment it implemented in the FY 2014 IPPS/LTCH PPS final rule to account for an estimated increase in Medicare expenditures due to the Two Midnight Policy.  Specifically, in the FY 2014 IPPS/LTCH PPS final rule, CMS estimated that this policy would increase expenditures and accordingly made an adjustment of

-0.2 percent to the payment rates.  CMS believes the assumptions underlying the -0.2 percent adjustment were reasonable at the time they were made.  Additionally, CMS does not generally believe it is appropriate in a prospective payment system to retrospectively adjust rates.  However, in light of recent review and the unique circumstances surrounding this adjustment, for FY 2017, CMS is permanently removing this adjustment and also its effects for FYs 2014, 2015, and 2016 by adjusting the FY 2017 payment rates.  This will increase FY 2017 payments by approximately 0.8 percent.


 

Medicare Uncompensated Care Payments
CMS distributes a prospectively determined payment amount to Medicare disproportionate share hospitals based on their relative share of uncompensated care nationally.  As required by the Affordable Care Act, this amount is equal to an estimate of 75 percent of what otherwise would have been paid as Medicare disproportionate share hospital payments prior to the Affordable Care Act, adjusted for decreases in the rate of uninsured individuals and other factors. In this rule, CMS is distributing almost $6 billion in uncompensated care payments in FY 2017, a decrease of approximately $400 million from the FY 2016 amount.

For FY 2017, CMS is finalizing a policy of continuing to distribute these funds using a proxy for uncompensated care based on insured low income days, which include inpatient days for patients eligible for Medicaid and inpatient days for patients entitled to Medicare and Supplemental Security Income (SSI).  CMS is also finalizing two changes to this methodology.  First, CMS will use data from three cost reporting periods instead of one cost reporting period to limit major fluctuations in uncompensated care payments from year-to-year. Second, CMS will apply a proxy to estimate Medicare SSI inpatient days for Puerto Rico hospitals since residents of Puerto Rico are not eligible for SSI benefits.

CMS proposed to begin incorporating uncompensated care cost data from Worksheet S-10 of the Medicare cost report in the methodology for distributing these funds starting in FY 2018.  In light of public comment, we are not finalizing this proposal. Instead, our intent is to engage in future rulemaking and begin to incorporate Worksheet S-10 data into the computation of Factor 3 no later than FY 2021.  We intend to make certain modifications and clarifications to the cost report instructions for Worksheet S-10, as well as implement review protocol for the Medicare Administrative Contractors (MACs) to use in reviewing Worksheet S-10. 

CMS-1632-F & IFC –Finalization of the Extension of the MDH Program and Low-Volume Hospital Adjustment Provided by the MACRA
On August 17, 2015, CMS issued an interim final rule with comment period (IFC) implementing the extension of the temporary changes to the criteria and payment adjustment for low-volume hospitals and the Medicare-dependent hospital (MDH) program for discharges occurring from April 1, 2015 through September 30, 2017, as provided by sections 204 and 205 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) of 2015 (Pub. L. 114-10). Under these extensions, a hospital can qualify as a low-volume hospital if it is located more than 15 road miles from another hospital and has fewer than 1,600 Medicare discharges, and special payment protections are retained for Medicare-dependent, small rural hospitals. We are finalizing this IFC in the FY 2017 IPPS/LTCH PPS final rule.

Notification Procedures for Outpatients Receiving Observation Services
Enacted August 6, 2015, the Notice of Observation Treatment and Implication for Care Eligibility Act (NOTICE Act) requires hospitals and Critical Access Hospitals (CAH) to provide notification to individuals receiving observation services as outpatients for more than 24 hours explaining the status of the individual as an outpatient, not an inpatient, and the implications of such status. 

  • Hospitals and CAHs are required to furnish a new proposed CMS-developed standardized notice, the Medicare Outpatient Observation Notice (MOON), to a Medicare beneficiary who has been receiving observation services as an outpatient for more than 24 hours. Under the final rule, hospitals and CAHs may deliver the MOON to individuals receiving observation services as an outpatient before such individuals have received more than 24 hours of observation services.  The notice must be provided no later than 36 hours after observation services are initiated or, if sooner, upon release;
  • The MOON will inform more than one million beneficiaries annually of the reason(s) they are an outpatient receiving observation services and the implications of such status with regard to Medicare cost sharing and coverage for post-hospitalization skilled nursing facility (SNF) services; and 
  • An oral explanation of the MOON must be provided, ideally in conjunction with the delivery of the notice, and a signature must be obtained from the individual, or a person acting on such individual’s behalf, to acknowledge receipt.  In cases where such individual or person refuses to sign the MOON, the staff member of the hospital or CAH providing the notice must sign the notice to certify that notification was presented.

The standardized notice, the MOON, is going through the Paperwork Reduction Act process, thus affording the public an opportunity to comment on the MOON.  The 30-day public comment period begins when the final rule is published.


 

Hospital-Acquired Condition (HAC) Reduction Program
The HAC Reduction Program creates an incentive for hospitals to reduce the incidence of hospital-acquired conditions by requiring the Secretary to make an adjustment to payments to hospitals that are in the worst performing quartile for hospital-acquired conditions. In the FY 2017 IPPS/LTCH PPS final rule, CMS is making five changes to existing HAC Reduction Program policies:

  1. Establishing National Healthcare Safety Network (NHSN) CDC Healthcare Associated Infections (HAI) data submission requirements for newly opened hospitals;
  2. Clarifying data requirements for Domain 1 scoring;
  3. Establishing performance periods for the FY 2018 and FY 2019 HAC Reduction Program;
  4. Adopting the refined PSI 90: Patient Safety for Selected Indicators Composite Measure (NQF # 0531); and
  5. Changing the Program scoring methodology from the current decile-based scoring to a continuous scoring methodology. 

Hospital Readmissions Reduction Program (HRRP)
The Hospital Readmission Reduction Program (HRRP) requires a reduction to a hospital’s base operating DRG payment to account for excess readmissions associated with selected applicable conditions. For FY 2017 and subsequent years, the reduction is based on a hospital’s risk-adjusted readmission rate during a three-year period for acute myocardial infarction (AMI), heart failure (HF), pneumonia, chronic obstructive pulmonary disease (COPD), total hip arthroplasty/total knee arthroplasty (THA/TKA), and coronary artery bypass graft (CABG) (pursuant to previous rulemaking). To align with other quality reporting programs and allow the posting of data as soon as possible, CMS is updating the public reporting policy so that excess readmission rates will be posted to the Hospital Compare website as soon as feasible following the hospitals’ preview period.

Medicare and Medicaid EHR Incentive Programs
This rule also includes the requirements for eligible hospitals and CAHs reporting clinical quality measures (CQMs) for the Medicare and Medicaid EHR Incentive Programs. CMS finalized modifications to some of the CQM reporting and submission requirements, including the proposed removal of certain CQMs to align with the Hospital IQR Program.

Hospital Inpatient Quality Reporting (IQR) Program
The Hospital IQR Program is a pay-for-reporting program established by the Medicare Prescription Drug, Improvement, and Modernization Act. In the FY 2017 IPPS/LTCH PPS final rule, CMS is finalizing the addition of four new claims-based measures for the FY 2019 payment determination and subsequent years (three clinical episode-based payment measures and one communication and coordination-of-care measure). CMS is also finalizing the removal of 15 measures for the FY 2019 payment determination and subsequent years.  Of these 15 measures, 13 are electronic clinical quality measures (eCQMs), two of which CMS is also removing in their chart-abstracted form, and two others are structural measures.  CMS is also finalizing the refinement of two previously adopted measures beginning with the FY 2018 payment determination. 

In addition, CMS is finalizing a number of changes in relation to eCQMs:

  1. Requiring hospitals to report four quarters of data on an annual basis for eight of the available eCQMs included in the Hospital IQR Program measure set for the FY 2019 and FY 2020 payment determinations in order to align with the Medicare and Medicaid EHR Incentive Programs.  This is a modification from the proposal, which proposed to require hospitals to submit on all available eCQMs (15 eCQMs) in the Hospital IQR Program;
  2. Requiring several related technical eCQM submission requirements beginning with the FY 2019 payment determination; and
  3. Expanding the current validation process to include the validation of eCQM data beginning in the spring of CY 2018 for the FY 2020 payment determination.

Lastly, CMS is finalizing an update to its Extraordinary Circumstances Extensions/Exemptions (ECE) policy by:

  1. Extending the ECE request deadline for non-eCQM circumstances from 30 to 90 calendar days following an extraordinary circumstance; and
  2. Establishing a separate submission deadline of April 1 following the end of the reporting calendar year for ECEs related to eCQMs.

Hospital Value-Based Purchasing (VBP) Program
Established by the Affordable Care Act, the Hospital VBP Program adjusts payments to hospitals for inpatient services based on their performance on an announced set of measures. In the FY 2017 IPPS/LTCH final rule, CMS is finalizing updates to the Hospital VBP Program requirements and the expansion of the Hospital VBP Program measure set. Specifically, the rule finalizes expanding the number of hospital units to which two National Healthcare Safety Network measures apply beginning with the FY 2019 program year. In addition, CMS is finalizing expansion of the cohort used to calculate the 30-day pneumonia mortality measure beginning with the FY 2021 program year. CMS is also finalizing the addition of two condition-specific payment measures (one for acute myocardial infarction and one for heart failure) beginning with the FY 2021 program year and a 30-day mortality measure following CABG surgery beginning with the FY 2022 program year. The rule also finalizes changes to the policy that governs whether a hospital will be excluded from the program if it is cited for deficiencies that pose immediate jeopardy to the health and safety of patients.

PPS-Exempt Cancer Hospital Quality Reporting (PCHQR) Program
The PCHQR Program collects and publishes data on an announced set of quality measures.  In the FY 2017 IPPS/LTCH PPS final rule, CMS is finalizing one new measure for this program.  Specifically, CMS is adding a measure of Admissions and Emergency Department Visits for Patients Receiving Outpatient Chemotherapy.  In addition to this measure, CMS is expanding the patient cohort of the previously finalized Radiation Dose Limits to Normal Tissues for Patients Receiving 3D Conformal Radiation Therapy measure.  The new cohort will include breast and rectal cancer patients in addition to the previous cohort of lung and pancreatic cancer patients.

Inpatient Psychiatric Facility Quality Reporting Quality Reporting (IPFQR) Program
The IPFQR Program is a pay-for-reporting program established by the Affordable Care Act. In the final rule, CMS is finalizing a technical update to the previously finalized measure, Screening for Metabolic Disorder.  CMS is also finalizing the addition of two new measures to the program beginning with the FY 2019 payment determination: (1) Thirty-day All-Cause Readmission Following Psychiatric Hospitalization in an IPF, which is a measure calculated from administrative claims data; and (2) SUB-3: Alcohol & Other Drug Use Disorder Treatment Provided or Offered at Discharge and the subset measure SUB-3a: Alcohol & Other Drug Use Disorder Treatment at Discharge (NQF #1664).  SUB-3/3a is a chart-abstracted measure that complements the previously adopted substance abuse measures in the IPFQR Program.

In addition, CMS is finalizing a policy to include the SUB-3/SUB-3a measure in the list of measures covered by the global sample for the FY 2019 payment determination and subsequent years.  The agency is also finalizing that it will make the data for the IPFQR Program available as soon as possible and announce both the date of public display of the program’s data and the 30 day preview period via sub regulatory methods.  CMS is also finalizing that we will no longer specify how long before public display the preview period will be; this timeframe was previously finalized as 12 weeks.  For the FY 2017 payment determination only, CMS is finalizing that, if it is technically feasible to display the data in December 2016, the Agency would provide data to IPFs for a two-week preview period that would start on October 1, 2016.  Moreover, CMS is finalizing that, for the FY 2017 payment determination only, if CMS is able to display the data in December 2016, the Agency would ensure that IPFs have approximately 30 days for review by providing IPFs with their data as early as mid-September.


 

Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) Changes
In this final rule, CMS is updating the LTCH PPS standard Federal payment rate by 1.75 percent for FY 2017 for LTCHs that successfully participate in the LTCH Quality Reporting Program (LTCH QRP).  This update is based on the most recent estimate of the revised and rebased LTCH PPS market basket (which is being adopted in this final rule) of 2.8 percent adjusted by ‑0.3 percentage point for multi-factor productivity and an additional adjustment of ‑0.75 percentage point in accordance with the Affordable Care Act.  CMS is also continuing to implement the changes required by The Pathway for SGR Reform Act of 2013 that establish two different types of LTCH PPS payment rates depending on whether the patient meets certain clinical criteria. As a result of the continued phase-in of these changes, CMS projects that LTCH PPS payments will decrease by 7.1 percent, or approximately $363 million in FY 2017 CMS. Cases that qualify for the higher standard LTCH PPS payment rate under the revised system will see an increase in payments of 0.7 percent in FY 2017. In addition, CMS is streamlining its regulations regarding the 25 percent threshold policy, which is a payment adjustment made when the number of cases an LTCH admits from a single hospital exceeds a specified threshold (generally 25 percent).

Along with the FY 2017 IPPS/LTCH PPS final rule, CMS finalized an IFC to implement section 231 of the Consolidated Appropriations Act, 2016 that established a temporary exception from the site neutral payment rate for certain severe wound care discharges from certain LTCHs. 

Long-Term Care Hospital (LTCH) Quality Reporting Program (QRP)
Beginning in FY 2014, the applicable annual update for any LTCH that did not submit the required data to CMS is reduced by two percentage points. The Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) requires the continued specification of quality measures for the LTCH QRP, as well as resource use and other measures.

In order to satisfy the requirements of the IMPACT Act, CMS is finalizing one new assessment-based quality measure, and three claims-based measures for inclusion in the LTCH QRP: 

  1. Discharge to Community – Post Acute Care (PAC) LTCH QRP (claims-based); 
  2. Medicare Spending Per Beneficiary (MSPB) – PAC LTCH QRP (claims-based);
  3. Potentially Preventable 30 Day Post-Discharge Readmission Measure for LTCHs (claims-based); and
  4. Drug Regimen Review Conducted with Follow-Up for Identified Issues (assessment-based). 

CMS is finalizing the addition of four new measures to LTCH QRP public reporting for fall 2017.  We are additionally clarifying the previously finalized procedures for provider review and correction of performance data in advance of LTCH QRP public reporting, in order to ensure we are aligned with the Hospital IQR Program’s policies and practices.

The final rule is available on the Federal Register here.

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 and has spoken for numerous organizations.

Contact the Author

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

Friday, 29 July 2016 14:38

How Many Stars Do You Have?

To some, it may have felt like we were back in grade school, waiting to see how many gold stars we would get on the homework we turned in.

Well, hospitals, the waiting is over. 

On July 27, the Centers for Medicare & Medicaid Services (CMS) released its hospital star ratings, despite pushback from many in the healthcare industry. Much of the pushback has centered on the belief that the star rating system is flawed, in that it does not take into account factors such as socioeconomic status and patients with multiple and complex conditions. In addition, hospitals are concerned that consumers may not truly understand the rating system limitations and that many factors should be evaluated when deciding on where to seek care, not only this one system.

The ratings reported for 4,599 hospitals were:

  • Five Stars:  2.2 percent
  • Four Stars:  20.3 percent
  • Three Stars:  38.5 percent
  • Two Stars:  15.7 percent
  • One Star:  2.9 percent

Safety net hospitals received slightly lower ratings, and some smaller hospitals were ineligible for reporting, as they did not have the data to report due to their small size.

So, what does this mean for hospitals? We have to remember that these ratings are based on data collected two years ago, so it is old data already. And while we may not all agree on the star ratings, it is what we have right now, so it is important that we take it seriously while continuing to provide input to CMS to improve the system as we move forward. Our best offense and defense is knowing where we stand on each measure so that we can focus on where to improve.

Data is the key element in analyzing outcomes. Basically, the data will let you know if you are experiencing success, and where you may need to focus on improvements. It will also determine how other organizations interpret what you are doing and how, as well as how you appear to your patients. You will want to ensure that medical record documentation is complete, as that will impact HIM (health information management) code assignment and quality abstracted data that is reported to various organizations. Patient experience data is also important to analyze how consumers view us – which may be very different from how we view ourselves. A list of the measures is provided at the end of this article.

In today’s healthcare environment, we must learn to do more with less, so whenever we can leverage technology to assist us, we should. Documentation is a good place to start, so be sure that your EHRs (electronic health records) are appropriately set up, especially across different patient care settings and services. Good data collection/reporting software to help ensure that accurate data is collected and transferred is also very important.

Ensure that optimal processes are established for quality data collection, internal reconciliation, monitoring, and reporting. This initiative should be led by the C-suite, with a strong organizational chart to ensure that all the players are identified, with expectations set for all roles.

Finally, it will be important to monitor how you are doing from both a patient outcomes/quality and financial perspective. Communication to the team will be important so that adjustments can be made in a timely manner.


 

To summarize, the healthcare industry is in the infancy stages of pay-for-performance and quality; however, it looks like they are here to stay. It will be very important for providers to monitor what is being reported and what the impacts are so that as this all progresses, we are better prepared and we can best report our outcomes in an evolving yet imperfect rating system.

Measures Include:

Mortality (7)

  • Death rate for heart attack patients
  • Death rate for coronary artery bypass graft (CABG) surgery patients
  • Death rate for chronic obstructive pulmonary disease (COPD) patients
  • Death rate for heart failure patients
  • Death rate for pneumonia patients
  • Death rate for stroke patients
  • Deaths among patients with serious treatable complications after surgery

Safety of Care (8)

  • Central line-associated bloodstream infections (CLABSI)
  • Catheter-associated urinary tract infections (CAUTI)
  • Surgical site infections from colon surgery (SSI: Colon)
  • Surgical site infections from abdominal hysterectomy (SSI: Hysterectomy)
  • Methicillin-resistant Staphylococcus Aureus (MRSA) Blood Laboratory-identified Events (Bloodstream infections)
  • Clostridium difficile (C.diff.) Laboratory-identified Events (Intestinal infections)
  • Rate of complications for hip/knee replacement patients
  • Serious complications

Readmission (8) 

  • Rate of unplanned readmission for heart attack patients
  • Rate of unplanned readmission for coronary artery bypass graft (CABG) surgery patients
  • Rate of unplanned readmission for chronic obstructive pulmonary disease (COPD) patients
  • Rate of unplanned readmission for heart failure patients
  • Rate of unplanned readmission after hip/knee surgery
  • Rate of unplanned readmission for pneumonia patients
  • Rate of unplanned readmission for stroke patients
  • Rate of unplanned readmission after discharge from hospital (hospital-wide)

Patient Experience (11) 

  • Patients who reported that their nurses communicated well
  • Patients who reported that their doctors communicated well
  • Patients who reported that they received help as soon as they wanted
  • Patients who reported that their pain was well controlled
  • Patients who reported that staff explained about medicines before giving it to them
  • Patients who reported that their room and bathroom were clean
  • Patients who reported that the area around their room was quiet at night
  • Patients who reported that they were given information about what to do during their recovery at home
  • Patients who understood their care when they left the hospital
  • Patients who gave their hospital a rating on a scale from 0 (lowest) to 10 (highest)
  • Patients who would recommend the hospital to their friends and family

Effectiveness of Care (18)

  • Children and their caregivers who received a home management plan of care document while hospitalized for asthma
  • Patients assessed and given influenza vaccination
  • Healthcare workers given influenza vaccination
  • Outpatients with chest pain or possible heart attack who received aspirin within 24 hours of arrival or before transferring from the emergency department
  • Percentage of patients who left the emergency department before being seen
  • Percentage of patients who came to the emergency department with stroke symptoms who received brain scan results within 45 minutes of arrival
  • Percentage of patients receiving appropriate recommendation for follow-up screening colonoscopy
  • Percentage of patients with history of polyps receiving follow-up colonoscopy in the appropriate timeframe
  • Percentage of mothers whose deliveries were scheduled too early (1-2 weeks early), when a scheduled delivery was not medically necessary
  • Ischemic or hemorrhagic stroke patients who received treatment to keep blood clots from forming anywhere in the body within 2 days of hospital admission
  • Ischemic stroke patients who got medicine to break up a blood clot within 3 hours after symptoms started
  • Ischemic stroke patients needing medicine to lower bad cholesterol, who were given a prescription for this medicine at discharge
  • Ischemic or hemorrhagic stroke patients or caregivers who received written educational materials about stroke care and prevention during the hospital stay
  • Patients who got treatment to prevent blood clots on the day of or day after hospital admission or surgery
  • Patients who got treatment to prevent blood clots on the day of or day after being admitted to the intensive care unit (ICU)
  • Patients with blood clots who got the recommended treatment, which includes using two different blood thinner medicines at the same time
  • Patients with blood clots who were discharged on a blood thinner medicine and received written instructions about that medicine
  • Patients who developed a blood clot while in the hospital who did not get treatment that could have prevented it

Timeliness of Care (7) 

  • Average (median) time patients spent in the emergency department, before they were admitted to the hospital as an inpatient
  • Average (median) time patients spent in the emergency department, after the doctor decided to admit them as an inpatient before leaving the emergency department for their inpatient room
  • Average (median) number of minutes before outpatients with chest pain or possible heart attack who needed specialized care were transferred to another hospital
  • Average (median) number of minutes before outpatients with chest pain or possible heart attack got an ECG
  • Average (median) time patients spent in the emergency department before leaving from the visit
  • Average (median) time patients spent in the emergency department before they were seen by a healthcare professional
  • Average (median) time patients who came to the emergency department with broken bones had to wait before getting pain medication

Efficient Use of Medical Imaging (5) 

  • Outpatients with low-back pain who had an MRI without trying recommended treatments first, such as physical therapy
  • Outpatient CT scans of the abdomen that were “combination” (double) scans
  • Outpatient CT scans of the chest that were “combination” (double) scans
  • Outpatients who got cardiac imaging stress tests before low-risk outpatient surgery
  • Outpatients with brain CT scans who got a sinus CT scan at the same time

For more information on the methodology for the star ratings, please see the Overall Hospital Quality Star Rating Methodology Report available on QualityNet.

About the Author

Kim Charland is the editor of VBPmonitor.com 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 and has spoken for numerous organizations.

Contact the Author

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

During a U.S. Senate Committee on Finance hearing yesterday on the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, Andy Slavitt, acting administrator for the Centers for Medicare & Medicaid Services (CMS), indicated that there could be some revisions to the proposed rule, including a possible delay in the January 1, 2017 proposed start date.

The hearing, which Committee Chairman Orrin Hatch (R-UT) and Ranking Member Ron Wyden (D-OR) led, was an opportunity for Slavitt to report on the number and types of comments that CMS received to the proposed rule. (CMS accepted comments until 5 p.m. on June 27, 2016.)  It is now up to CMS to process all the comments and determine how to best revise and respond to them.

It has been well-publicized that CMS has received many comments from healthcare entities such as providers, vendors, and health plans. One of the biggest concerns from the point of the eligible provider (EP) is the timeline of MACRA for implementation, which is currently scheduled to begin in 2017 with bonuses being paid out to EPs in 2019.

Chairman Hatch states that the MACRA law gives CMS the flexibility to move the start date of the reporting period back. The current timeline it only gives EPs about two months to prepare for this major revision—a key concern especially for single EPs and smaller physician practices.

A definite decision on the implementation date will not be available until CMS publishes the final rule, which is expected in late October or early November.

Key Components of Proposed MACRA Rule

Merit-Based Incentive Payment System (MIPS)

  • The renaming of “EPs” to MIPS eligible clinicians, which will include physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, and groups that include such clinicians. The rule proposes definitions and requirements for groups. The rule also proposes excluding specific Medicare-enrolled practitioners, including newly Medicare-enrolled eligible clinicians, qualifying APM participants (QPs), certain partial qualifying APM participants (Partial QPs), and clinicians that fall under the proposed low-volume threshold.
  • MIPS performance standards and a MIPS performance period of one calendar year (Jan. 1 through Dec. 31) for all measures and activities applicable to the four performance categories.
  • Using 2017 as the performance period for the 2019 payment adjustment. Therefore, the first performance period would start in 2017 for payments adjusted in 2019.
  • Four performance categories: quality, resource use, clinical practice improvement activities (CPIAs), and meaningful use of certified EHR technology (referred to in this proposed rule as “advancing care information”).
  • Quality measures selected annually through a call for a quality measures process. Selection of these measures is proposed to be based on certain criteria that align with CMS priorities, and a final list of quality measures will be published in the Federal Register by Nov. 1 of each year.
  • Quality measures: For most MIPS-eligible clinicians, a minimum of six measures with at least one cross-cutting measure (for patient-facing MIPS-eligible clinicians) and an outcome measure will be used, if available; if an outcome measure is not available, then the eligible clinician would report one other high-priority measure (appropriate use, patient safety, efficiency, patient experience, or care coordination measures) in lieu of an outcome measure.
  • Resource use: Continuation of two measures from the VM: total per costs capita for all attributed beneficiaries and Medicare spending per beneficiary (MSPB), with minor technical adjustments. In addition, episode-based measures, as applicable to the MIPS eligible clinician, will be applied.
  • Clinical practice improvement activity (CPIA): a minimum number of CPIAs will be encouraged but not required.
  • Advancing care information (meaningful use): an assessment based on advancing care information measures and objectives will be performed.
  • A process for providing performance feedback to MIPS-eligible clinicians. Beginning July 1, 2017, it is proposed to include information on the quality and resource use performance categories in the performance feedback.

Alternative Payment Models (APMs)

  • Definitions of APMs, including other payor APMs, APM entities, and advanced APMs
  • Requirements for participation and incentive payments
  • A process for eligible clinicians to choose whether to be subject to the MIPS payment adjustment in the event that they are determined to be partial QPs
  • A definition for physician-focused payment models (PFPMs), criteria that would be used by the PFPM Technical Advisory Committee (PTAC), the HHS secretary, and CMS to evaluate proposals for PFPMs, and the process by which PFPMs would be considered for testing and implementation by CMS after review by the PTAC.

Data-Sharing Requirement

This would require MIPS-eligible clinicians as well as EPs, eligible hospitals, and critical access hospitals (CAHs) under the existing EHR incentive programs to make a demonstration related to the provisions concerning blocking the sharing of information under section 106(b)(2) of the Medicare Access and CHIP Reauthorization Act of 2015(MACRA) and, separately, to demonstrate cooperation with authorized ONC surveillance of certified EHR technology.

About the Author

Kim Charland is the editor of VBPmonitor.com 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 and has spoken for numerous organizations.

Contact the Author

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

Tuesday, 22 March 2016 07:02

VBPmonitor is One Year Old!

I would like to thank all of you who have subscribed and supported VBPmonitor this past year. It is hard to believe that one year ago today, on March 23, 2015, we announced its launch, marking Panacea Healthcare Solutions’ newest “monitor” product: an Internet news platform created to help providers navigate through the value-based purchasing and quality maze. The centerpiece is the VBPmonitor.com website, which not only features articles written for the many different value-based purchasing (VBP) initiatives, but also features VBPUniversity.com, which produces educational webcasts and offers white papers and books. If you haven’t visited that website yet, please do.

I would also like to thank the VBPmonitor Editorial Board for its continuous support and expert clinical content, which has made up the articles in our e-newsletters, white papers, and webcasts. Thanks to them we have covered news topics such as the Hospital Value-Based-Purchasing Program, Hospital Readmission Reduction Program, Hospital-Acquired Conditions (HACs), Core Measures, the CJR Final Rule, the Physician Quality Reporting System (PQRS), the Value-Based Modifier Program, Meaningful Use, Accountable Care Organizations (ACOs), the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) Work Plan, the impact of ICD-10 on quality reporting, best practices from actual providers, and the LTPAC (Long-Term Post-Acute Care) Health IT Collaborative, to name a few. All of these topics (and more) are searchable in our e-news archives and can be accessed by going to the VBPmonitor home page; just click on the NEWS tab at the top of page and then click on ENEWS. You can also click on the Editorial Board tab to view who is involved in the process of producing the news. We are always looking for additional members, so if you are interested, please contact me directly at This email address is being protected from spambots. You need JavaScript enabled to view it..

This is truly an exciting time in healthcare, as we really begin to transform from fee-for-service to value-based reimbursement.  A recent HHS press release issued on March 3 noted that “an estimated 30 percent of Medicare payments are now tied to alternative payment models that reward the quality of care over quantity of services provided to beneficiaries.” There have also been recent discussions on the financial impact in relation to drops in profits, revenue, and income, and increased costs related to technology needs, process changes, etc. that this move is having on providers. While I believe everyone agrees that increasing quality in healthcare is very important, these next few years will be interesting to watch in order to see how this all plays out – and VBPmonitor will be with you every step of the way!

So, what’s coming to VBPmonitor in the next year? We will be continuing to bring you our free e-newsletter delivered directly to your inbox, as well as special bulletins when there is breaking news. We are planning an exciting schedule of webcasts and white papers as well as looking to begin our free live weekly internet broadcast, Thought-Leader-Thursday, which is scheduled to launch sometime this summer. You can access all this information on our website, www.VBPmonitor.com.

Again, thank you so very much for all your support this past year.

 

About the Author

Kim Charland is the editor of VBPmonitor.com 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 and has spoken for numerous organizations.

Contact the Author

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



The Tax Relief and Health Care Act of 2006 mandated that the Centers for Medicare & Medicaid Services (CMS) establish the Hospital Outpatient Quality Reporting (OQR) Program. In general, outpatient measures evaluate the regularity with which a healthcare provider administers the outpatient treatment known to provide the best results for the most patients with a particular condition. This program requires acute-care hospitals to submit data on quality-of-care measures furnished in outpatient settings that assess:

  • Cardiac care
  • Emergency department (ED) throughput
  • Pain management
  • Stroke
  • Surgical care
  • Imaging efficiency
  • Web-based activities

Hospitals that report data using the above standardized measures of care receive the full annual up­date to their outpatient prospective payment system (OPPS) payment rate. Those that do not receive a 2-percentage point reduction in their annual OPPS update.

The measures for payment determination for hospitals participating in the Hospital Outpatient Quality Reporting (OQR) program are provided in the following table.

Hospital OQR Quality Measures

OP-1

Median Time to Fibrinolysis

OP-2 Fibrinolytic Therapy Received Within 30 Minutes of ED Arrival
OP-3 Median Time to Transfer to Another Facility for Acute Coronary Intervention
OP-4 Aspirin at Arrival
OP-5 Median Time to ECG
OP-6 Timing of Antibiotic Prophylaxsis - MEASURE REMOVED*
OP-7 Prophylactic Antibiotic Selection for Surgical Patients - MEASURE REMOVED*
OP-8 MRI Lumbar Spine for Low Back Pain
OP-9 Mammography Follow-up Rates
OP-10 Abdomen CT Use of Contrast Material
OP-11 Thorax CT Use of Contrast Material
OP-12 The Ability for Providers with HIT to Receive Laboratory Data Electronically Directly into their ONC-Certified EHR System as Discrete Searchable Data
OP-13 Cardiac Imaging for Preoperative Risk Assessment for Non-Cardiac Low-Risk Surgery
OP-14 Simultaneous Use of Brain Computed Tomography (CT) and Sinus CT
OP-15 Use of Brain CT in the Emergency Department (ED) for Atraumatic Headache - REPORTING POSTPONED**
OP-17 Tracking Clinical Results between Visits
OP-18 Median Time from ED Arrival to ED Departure for Discharged ED Patients
OP-19 Transition Record with Specified Elements Received by Discharged Patients - MEASURE REMOVED***
OP-20 Door to Diagnostic Evaluation by a Qualified Medical Professional
OP-21 ED-Median Time to Pain Management for Long Bone Fracture
OP-22 ED-Patient Left Without Being Seen
OP-23 ED-Head CT or MRI Scan Results for Acute Ischemic Stroke or Hemorrhagic Stroke who Received Head CT or MRI Scan Interpretation Within 45 Minutes of Arrival
OP-25 Safe Surgery Checklist Use
OP-26

Hospital Outpatient Volume Data on Selected Outpatient Surgical Procedures

(For a complete list of procedure category and corresponding codes affected, refer to the Hospital OQR Program Specifications Manual.)

OP-27 Influenza Vaccination Coverage Among Healthcare Personnel (reported on the National Healthcare Safety Network website)
OP-29 Endoscopy/Polyp Surveillance: Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients
OP-30 Endoscopy/Polyp Surveillance: Colonoscopy Interval for Patients with a History of Adenomatous Polyps – Avoidance of Inappropriate Use
OP-31 Cataracts – Improvement in Patient’s Visual Function Within 90 Days Following Cataract Surgery†***
OP-32 Facility 7-Day Risk-Standardized Hospital Visit Rate after Outpatient Colonoscopy†

https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=QnetPublic%2FPage%2FQnetTier3&cid=1192804531207

I’ve been speaking and writing a lot lately about the inpatient quality programs and how data quality, technology, processes, and outcomes are impacting us. These items are also important for the outpatient side of our quality business. The financial impact may be less, but the quality outcomes and patient experience make them equally relevant.


 

Data: Data is the key element in analyzing outcomes. Basically, the data will let you know if you are experiencing success and where you may need to focus on improvements. It will also determine how other organizations interpret what you are doing and how, as well as how you appear to your patients. You will want to ensure that medical record documentation is complete, as that will impact HIM (health information management) code assignment and quality abstracted data that is reported to various organizations.

Technology: In today’s healthcare environment we must learn do more with less, so whenever we can leverage technology to assist us, we should. Documentation is a good place to start, so be sure that your EHRs (electronic health records) are appropriately set up, especially across different patient care settings and services. Good data collection/reporting software to help ensure that accurate data is collected and transferred is also very important.

Processes: Ensure that optimal processes are established for quality data collection, internal reconciliation, monitoring, and reporting. This initiative should be led by the C-suite, with a strong organizational chart to ensure that all the players are identified, with expectations set for all roles.

Impact on patient outcomes and financial results: Finally, it will be important to monitor how you are doing from both a patient outcomes/quality and financial perspective. Communication to the team will be important so that adjustments can be made in a timely manner.

To summarize, the healthcare industry is in the infancy stages of pay-for-performance and quality; however, it looks like they are here to stay. It will be very important for providers to monitor what is being reported and what the impact is so that as this all progresses, we are better prepared.

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, which is the company’s newest Internet news and information platform focused on value-based purchasing and quality. She is also co-host of ICD10monitor’s weekly 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 and has spoken for numerous organizations.

Contact the Author

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

Page 1 of 2