2017 IPPS Proposed Rule fuels continued commitment to eCQM reporting for IQR

On April 18, 2016, CMS issued the 2017 IPPS proposed rule continuing their commitment to eCQM reporting for the IQR program. The rule proposes to continue a commitment to increasingly shift Medicare payments from volume to value. CMS has set goals and timelines to move the Medicare program, and the health care system at large, toward paying providers based on the quality, rather than the quantity of care they provide patients.

We are rapidly progressing toward value-based care models fueled by electronic clinical quality measure reporting. Healthcare organizations will no longer be motivated by implementing and meeting Meaningful Use, but instead will be driven by value-based care and risk-based payment models that focus on quality outcomes for reimbursements.

The proposed rule will require hospitals to report a full year, four quarters of data for all eCQMs included in the Hospital IQR Program measure set in 2017 and subsequent years in order to align with Medicare and Medicaid EHR Incentive Programs (Meaningful Use). CMS is also proposing to remove 15 measures for the CY 2017 reporting period and subsequent years. Of these 15 measures, 13 are electronic clinical quality measures (eCQMs), two of which CMS is also proposing to remove in their chart-abstracted form, and two others are structural measures. CMS is also proposing to refine two previously adopted measures beginning with the CY 2016 reporting period, the Hospital-level, Risk-standardized Payment Associated with a 30-day Episode-of-Care for Pneumonia and the Patient Safety and Adverse Events Composite.

In addition, CMS is proposing a number of changes in relation to eCQMs:
Require hospitals to submit all available eCQMs included in the Hospital IQR Program measure set for four quarters of data, on an annual basis, beginning with the CY 2017 reporting period.
To remove 13 electronic clinical quality measures (eCQMs) for the CY 2017 reporting period.
To modify the current validation process to include the validation of eCQM data beginning in the spring of CY 2018 reporting period.

Electronic clinical quality measures (eCQM):
CMS is proposing to remove the electronic versions of AMI-7a, HTN, PN-6, SCIP-Inf-9, VTE-3, VTE-4, VTE-5, VTE-6, STK-4, AMI-2, AMI-10, SCIP-Inf-1a, and SCIP-Inf-2a, beginning with the CY 2017 reporting period.

CMS is proposing to remove 13 eCQMs from both the Hospital IQR Program and the Medicare and Medicaid EHR Incentive Programs in order for hospitals to focus on a smaller, more specific subset of eCQMs while keeping the programs aligned.

CMS has finalized the following eCQMs:

• AMI-8a - Primary PCI Received Within 90 Minutes of Hospital Arrival
• CAC-3 - Home Management Plan of Care Document Given to Patient/Caregiver
• ED-1 - Median Time from ED Arrival to ED Departure for Admitted ED Patients
• ED-2 - Admit Decision Time to ED Departure Time for Admitted Patients
• EHDI-1a - Hearing Screening Prior to Hospital Discharge 1354
• PC-01 - Elective Delivery (Collected in aggregate, submitted via Web-based tool or electronic clinical quality measure)
• PC-05 - Exclusive Breast Milk Feeding
• STK-02 - Discharged on Antithrombotic Therapy
• STK-03 - Anticoagulation Therapy for Atrial Fibrillation/Flutter
• STK-05 - Antithrombotic Therapy by the End of Hospital Day Two
• STK-06 - Discharged on Statin Medication
• STK-08 - Stroke Education
• STK-10 - Assessed for Rehabilitation
• VTE-1 - Venous Thromboembolism Prophylaxis
• VTE-2 - Intensive Care Unit Venous Thromboembolism Prophylaxis

Chart- Abstraction:
The proposal includes removing two measures in their chart-abstracted forms STK-4 and VTE-5. The removal is because measure performance among hospitals is so high and unvarying that meaningful distinctions and improvements in performance can no longer be made.
Hospitals must submit a full calendar year of data (covering Q1, Q2, Q3, and Q4) via chart-abstraction regardless of whether data also are submitted electronically in accordance with the applicable submission requirements. CMS has finalized the following chart-abstraction measure set:

• ED-1 - Median Time from ED Arrival to ED Departure for patients Admitted ED Patients
• ED-2 - Admit Decision Time to ED Departure Time for Admitted Patients
• Imm-2 - Influenza Immunization
• PC-01 - Elective Delivery (Collected in aggregate, submitted via Web-based tool or electronic clinical quality measure)
• Sepsis - Severe Sepsis and Septic Shock: Management Bundle (Composite Measure)
• VTE-6 - Incidence of Potentially Preventable Venous Thromboembolism

The rule proposes updates to the Hospital-Acquired Condition Reduction Program, Hospital Readmissions Reduction Program and Hospital Value-Based Purchasing Program.

Hospital Acquired Conditions (HAC) Reduction Program:
CMS will continue to provide incentives for hospital to reduce the incidence of hospital-acquired conditions by making an adjustment to payments to hospitals that are in the worst performing quarterile for prevalence of hospital-acquired conditions. CMS is proposing to make five changes to existing HAC Reduction Program policies:

• Establish NHSN CDC HAI data submission requirements for newly opened hospitals;
• Clarify data requirements for Domain 1 scoring;
• Establish performance periods for the FY 2018 and FY 2019 HAC Reduction Programs;
• Adopt the refined PSI 90: Patient Safety for Selected Indicators Composite Measure (NQF # 0531); and 
• Change the Program scoring methodology from the current decile-based scoring to a continuous scoring methodology.

Hospital Readmissions Reduction Program (HRRP):
The HRRP requires a reduction to a hospital’s base operating DRG payment to account for excess readmissions associated with selected applicable conditions. CMS is proposing to update 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.

Hospital Value-Based Purchasing (VBP) Program:
The Hospital VBP Program adjusts payments to hospitals for inpatient services based on their performance on an announced set of measures. CMS proposes to expand the number of hospital units to which two National Healthcare Safety Network measures apply beginning with the FY 2019 program year. In addition, CMS proposes to expand the cohort used to calculate the 30-day pneumonia mortality measure beginning with the FY 2021 program year. CMS also proposes to add 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.

eCQM validation process: 
CMS believes that it is increasingly important to validate eCQM data to ensure the accuracy of future information submitted by hospitals and reported to the public. Therefore, CMS is proposing to adopt a validation process for eCQM data submissions beginning in spring of CY 2018. The proposed validation process will consist of eCQM data submitted by up to 200 hospitals selected via random sample.  If a hospital is selected for chart-abstracted targeted or random validation, that hospital would be excluded from the eCQM validation sample. Adding the proposed eCQM validation would result in a total of 800 hospitals in the validation process, as described in the below tables.



CMS will accept comments on the proposed rule until June 16, 2016, and will respond to comments in a final rule to be issued by August 1, 2016. The proposed rule can be downloaded from the Federal Register at: https://www.federalregister.gov/articles/2016/04/27/2016-09120/medicare-program-hospital-inpatient-prospective-payment-systems-for-acute-care-hospitals-and-the

- See more at: http://www.acmeware.com/posts/2016/april/2017-ipps-proposed-rule-for-iqr