Friday, August 12, 2016

2017 IPPS Rule Continues Commitment from Volume to Value Defined by eCQMs

CMS expands electronic clinical quality measure (eCQM) reporting in the Hospital IQR Program

On August 2, 2016, CMS issued a final rule continuing their commitment to eCQM reporting for the IQR program while increasingly shift Medicare payments from volume to value.
CMS believes that the use of certified EHRs can effectively and efficiently help providers improve internal care delivery practices, support the exchange of important information across care partners and during transitions of care, and enable the reporting of electronically specified clinical quality measures (eCQMs).

The rule finalized updates to multiple value-based care initiatives, such as the Hospital Inpatient Quality Reporting program, the EHR Incentive Program, the Hospital Value-Based Purchasing system, Hospital-Acquired Condition Reduction program, and Long-Term Care Hospital (LTCH) Quality Reporting Program (QRP).  The final rule includes updates defined in the 2017 IPPS Proposed Rule. This summary will focus on Hospital Inpatient Quality Reporting program changes related to eCQMs, Chart-Abstraction and the EHR Incentive Program.

Hospital Inpatient Quality Reporting (IQR) Program:
CMS finalized 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.

Summary of changes:
Removal of 13 eCQMs
Submission of 8 self-selected eCQMs out of the available eCQMs for the CY 2017
Requirement for annual submission of 4 quarters of eCQM data
Required use of EHR technology certified to the 2014 or 2015 Edition of CEHRT for CY 2017 reporting period
Required submission of eCQM data by the end of 2 months following the close of the reporting period calendar year

Electronic clinical quality measures (eCQM):
CMS has removed 13 eCQMs from both the Hospital IQR Program and the Medicare and Medicaid EHR Incentive Programs (Meaningful Use) in order for hospitals to focus on a smaller, more specific subset of eCQMs while keeping the programs aligned.
CMS finalized the removal of electronic versions of AMI-2, AMI-7a, AMI-10, HTN, PN-6, SCIP-Inf-1a, SCIP-Inf-2a, SCIP-Inf-9, VTE-3, VTE-4, VTE-5, VTE-6, and STK-4 beginning 
with the CY 2017 reporting period.



CMS has finalized the following eCQMs for 2017:
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

In addition, CMS has finalized a number of changes in relation to eCQMs: 


  1. Hospitals must report a full year, 4 quarters of data on an annual basis for 8 of the available eCQMs included in the Hospital IQR Program measure set starting in CY 2017 in order to align with the Medicare and Medicaid EHR Incentive Programs.
  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.
  4. The CMS has modified the existing validation process for the Hospital IQR Program data to include a random sample of up to 200 hospitals for validation of eCQMs


Chart- Abstraction:
The final rule includes removing two measures in their chart-abstracted forms STK-4 and VTE-5. The removal is a long-term effort to move quality measurement toward outcomes measures and electronic clinical quality measures. 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:


CMS has finalized the following chart-abstraction measures:

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

Medicare and Medicaid EHR Incentive Programs:
CMS has finalized the following changes:

For manual attestation:
If only participating in the EHR Incentive Program, report on all 16 available CQMs.

For electronic reporting:
If only participating in the EHR Incentive Program, or participating in both the EHR Incentive Program and the Hospital IQR Program, report on 8 of the available CQMs

Penalties:
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 Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Final Rule Policy and Payment Changes for Fiscal Year (FY) 2017