Remove – Remove – Remove!

CMS’s strategy for a holistic quality payment program, the FY 2019 IPPS Final Rule, involves several removed measures to prevent duplication across programs in which is stated as considered causing unnecessary complexity or unnecessary costs. This focus on removal is ultimately positive and will help reduce administrative burden on providers.

“Regulatory reform and reducing regulatory burden are high priorities for CMS.” (CMS, FY 2019 IPPS Final Rule)

Through the Meaningful Measures Initiative and its impact, the strategy is to reduce regulatory burden by finalizing the following changes to the various quality programs, including Inpatient Quality Reporting (IQR) Program, Hospital Value-Based Purchasing (VBP) Program, Hospital-Acquired Conditions (HAC) Program, and Readmissions Reduction Program.

Meaningful Measures Hub: www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityInitiativesGenInfo/MMF/General-info-Sub-Page.html

Inpatient Quality Reporting (IQR) Program

Estimated dollar savings and hours savings shown above are based on 3,300 IPPS hospitals. Additional costs unrelated to data collection are anticipated to be realized from the removal of various measures.

Overall changes to the program include:

• Adding a new measure removal factor (Factor 8) to determine if the continued use of a measure will end up with greater costs associated and outweigh the benefit
• Removing a total of 39measures from FY 2020 through FY 2023
  • Two (2) structural patient safety measures
  • Six (6) patient safety measures
  • Four (4) chart-abstracted clinical process of care measures
  • Seven (7) claim-based coordination of care measures
  • Five (5) claims-based mortality measures
  • One (1) claim-based patient safety measure
  • Seven (7) claims-based payment measures
  • Seven (7) EHR-based clinical process of care measures (eCQMs)

Homepage:www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HospitalQualityInits/HospitalRHQDAPU.html

Hospital Value-Based Purchasing (VBP) Program

Since the amount available for value-based incentive payments under the program each year must be equal to the total amount of base operating MSDRG payment amount reductions for that year, CMS estimates no net financial impact for FY 2019 VBP. The amount available is estimated to be $1.9 billion.

Overall changes to the program include:

• Clinical domain has been renamed Clinical Outcomes domain
• Removal of four (4) measures:

1. Acute Myocardial Infarction – Hospital-Level, Risk-Standardized Payment Associated with a 30-Day Episode-of-Care (for FY 2019)
2. Heart Failure – Hospital-Level, Risk-Standardized Payment Associated with a 30-Day Episode-of-Care (for FY 2019)
3. Pneumonia – Hospital-Level, Risk-Standardized Payment Associated with a 30-Day Episode-of-Care (for FY 2019)

Why? Due to duplication. These will continue to be used in the Hospital IQR program

4. Elective Delivery (for FY 2021)

Why? Cost of measure outweighs benefit of its continued use

Hospital Value-Based Purchasing FACT SHEET: www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/Hospital_VBPurchasing_Fact_Sheet_ICN907664.pdf

Homepage:www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/HVBP/Hospital-Value-Based-Purchasing.html

Hospital-Acquired Condition (HAC) Reduction Program

CM states any significant impact, including the hospitals to receive a HAC adjustment, will depend on actual experience.

Overall changes to the program include:

• Establish the applicable period for FY 2021
• Beginning January 1, 2020: Establish administrative policies to collect, validate, and publicly report NHSN healthcare-associated infection (HAI) quality measure data that facilitate a seamless transition, independent of the Hospital IQR Program
• Scoring methodology by removing domains and assigning equal weighting to each measure for which a hospital has a measure

Readmissions Reduction Program

For FY 2019 and subsequent years, reduction is based on a hospital’s risk-adjusted readmission rate during a 3-year period for:

• Acute myocardial infarction (AMI)
• Heart failure (HF)
• Pneumonia
• Chronic obstructive pulmonary disease (COPD)
• Total hip arthroplasty/total knee arthroplasty (THA/TKA)
• Coronary artery bypass graft (CABG)

CMS estimates 2,610 hospitals will receive reduced operating payments due to the readmissions reduction program, producing a savings of approximately $566 million.

Homepage:www.cms.gov/medicare/medicare-fee-for-service-payment/acuteinpatientpps/readmissions-reduction-program.html

Medicare and Medicaid Promoting Interoperability Program

Overall changes to the program include:

• An EHR reporting period of a minimum of any continuous 90 days in CYs 2019 and 2020 for new and returning participants attesting to CMS or their State Medicaid agency
• Modifications to proposed performance-based scoring methodology (now a smaller set of objectives, smaller set of new and modified measures)
• Removal of certain CQMs beginning with the reporting period in CY 2020 as well as the CY 2019 reporting requirements to align the CQM reporting requirements for the Promoting Interoperability Programs with the Hospital IQR Program
• Codification of policies for subsection (d) Puerto Rico hospitals
• Amendments to the prior approval policy applicable in the Medicaid Promoting Interoperability Program to align with the prior approval policy for MMIS and ADP systems and to minimize burden on States
• Deadlines for funding availability for States to conclude the Medicaid Promoting Interoperability Program

Homepage: www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/index.html?redirect=/EHrIncentivePrograms