By Jan. 2011, as outlined in the FY 2011 final Inpatient Prospective Payment System (IPPS) rule, CMS will require all hospitals participating in the IPPS to:
- enroll in the Center for Disease Control and Prevention’s (CDC) National Healthcare Safety Network (NHSN); and
- collect and report data on specific central line-associated bloodstream infections (CLABSIs).
Those that do not meet these requirements by Jan. 2011 and do not submit data to CDC/NHSN will be subject to a two percentage point reduction in their Medicare inpatient annual payment update for FY 2013. Going forward, surgical site infections reporting will begin in 2012 with associated payment impact effective in 2014, and additional measures will likely be introduced in the future.
From a reporting standpoint, along with the IPPS rule, performance data collected through NHSN will be made public on CMS’ Hospital Compare website and could be incorporated into future reform policies such as value-based purchasing.
Why NHSN
NHSN is a voluntary, secure, Web-based surveillance system that integrates and expands legacy patient and healthcare personnel safety surveillance systems managed by the CDC. It has the capacity for providers to share data in a secure, timely manner between facilities in a multihospital system or with other entities, including public health agencies or quality improvement organizations.
NHSN allows for validated estimations of both the magnitude of adverse events among patients and healthcare personnel and adheres to practices known to be associated with prevention of HAIs. Using NHSN can help providers with prevention through the recognition of trends, and it provides consumers with the most accurate and reliable information about their healthcare facilities.
Prepare to report, continue to improve safety
Many providers are making progress toward meeting NHSN infection reporting requirements. Currently, 21 states are required to report to NHSN, and the CDC says there are approximately 3,000 of the nearly 3,500 hospitals subject to the pay-for-reporting requirements registered with NHSN. According to a recent Premier healthcare alliance survey of more than 560 hospital representatives, nearly 60 percent of respondents suggest their facilities are already enrolled in NHSN. But, only 41 percent are both enrolled and presently submitting CLABSI data.
The following are five key steps hospitals can take to properly prepare for and meet the current and future IPPS ruling reporting requirements and to avoid penalties, while improving patient safety and quality of care:
1. Benchmark performance against others, particularly top performers. How better to improve than to leverage the successes of peers? The use of benchmarking data is a key means to informing providers of how they compare against their peers, and it also serves as an excellent way to drive change, as no one wants to see their facility’s name at the bottom of a performance ranking. Providers should use the data to set targets and strive toward top performance. Collaborative, peer-to-peer projects that stress transparency are optimal settings for benchmarking and performance improvement.
2. Focus on actionable information. Though an essential ally, data does not, unto itself, prevent HAIs such as CLABSIs. To truly be effective, data needs to be timely, accurate, correctly presented and interpreted in the right context to positively impact outcomes. It need not be perfect, just good enough to accomplish the task at hand and trigger prevention opportunities.
3. Improve physician alignment. A decrease in budgets coupled with an increase in the evaluation of professional practice quality enhances the need for hospitals to find ways to align physicians with organization goals. One way to effectively achieve alignment is through the use of physician champions to openly and constructively confront and diffuse inevitable pushback and dismissals that will arise. A physician champion should embody equal parts diplomacy, tact and “emotional intelligence” to be successful.
4. Better indentify and code POAs. Present on admission (POA) codes were developed as a way for CMS to electronically identify conditions that were preexisting before hospital admission. Since existing and upcoming regulations do/will reduce payment for cases in which infections were acquired in a healthcare setting, the inability to properly identify and/or code infections as POA can cost providers millions. Hospitals need to address their coding practice and find opportunities to identify and rectify gaps in this practice.
5. Business case for technology. Manual identification of infections is costly, time-consuming and diverts staff time from prevention activities. Recent publications demonstrate hospitals that invest in computerized systems to identify and monitor HAIs are more likely to implement best practices to prevent such infections (www.ama-assn.org/amednews/2010/08/02/bisg0805.htm). Automated surveillance allows for rapid and thorough review of relevant data, promoting swift identification of serious events and recognition of outbreaks. It also requires less staff time than manual surveillance methods, allowing clinicians to effectively implement transmission prevention processes. Furthermore, automated systems can facilitate proper antibiotic utilization by monitoring and tracking usage, resistance patterns and adverse drug events.
The final Medicare IPPS policies incorporate numerous quality measures that hospitals should understand to avoid payment cuts. The ability to compare against others, focus on actionable information, properly work with physicians, use appropriate coding and make changes in performance will help hospitals steer clear of these cuts while advancing patient safety and the quality of care they provide.
Salah S. Qutaishat, Ph.D., CIC, FSHEA, is director of epidemiology and surveillance systems, Premier healthcare alliance.
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