Quality Measures in the IPPS Rule: Proposed vs. Final

In its final rule for the fiscal year 2014 Hospital Inpatient Prospective Payment System, CMS changed some of its proposed quality program requirements.

Here is an overview of some of the major changes to quality-related requirements made from the proposed to the final IPPS rule.

Hospital-Acquired Condition Reduction Program

Proposed: CMS' proposed Hospital-Acquired Condition Reduction Program for FY 2015 included a 1 percent payment reduction to the 25 percent of hospitals with the most hospital-acquired infections, based on a Total HAC Score. CMS proposed calculating the Total HAC Score by scoring hospitals in the top quartile for each measure in two domains, adding the scores within each domain and multiplying each sum by a proposed weight — 50 percent for each domain — and finally adding these weighted domain scores.

CMS proposed six measures developed by the Agency for Health Care Research and Quality to comprise domain 1:  pressure ulcer rate, volume of foreign object left in the body, iatrogenic pneumothorax rate, postoperative physiologic and metabolic derangement rate, postoperative pulmonary embolism or deep vein thrombosis rate and accidental puncture or laceration rate.

CMS also proposed an alternative to domain 1: a single AHRQ PSI-90 composite, which includes eight measures — pressure ulcer rate, iatrogenic pneumothorax rate, central venous catheter-related bloodstream infection rate, postoperative hip fracture rate, postoperative pulmonary embolism or deep vein thrombosis rate, postoperative sepsis rate, postoperative wound dehiscence rate and accidental puncture and laceration rate.

CMS proposed including two measures developed by the Centers for Disease Control and Prevention's National Health Safety Network measures — central line-associated blood stream infection and catheter-associated urinary tract infection — in domain 2 for FY 2015. It suggested adding surgical site infections for FY 2016 and methicillin-resistant Staphylococcus aureus and Clostridium difficile in FY 2017.

Final: The final rule adopted the alternative for domain 1 — the PSI-90 composite — and finalized its proposal for domain 2. It changed the methodology for creating the Total HAC Score such that "points will be assigned for each measure in deciles between the score of the best performing hospital and the worst performing hospital." This method assigns points to all hospitals from the best- to worst-performing instead of assigning points to only the hospitals in the top quartile for a specific measure, according to the final rule. In addition, domain 1 will be weighted 35 percent and domain 2 will be weighted 65 percent instead of having equal weights. As proposed, the 25 percent of hospitals with the highest Total HAC Score will receive 99 percent of the payment they would otherwise receive for discharges beginning in FY 2015.

Hospital Readmissions Reduction Program

Proposed: CMS proposed expanding a methodology to account for planned readmissions in penalty calculations beginning in FY 2014 and adding hip/knee surgery and chronic obstructive pulmonary disease 30-day readmissions for calculations beginning in FY 2015.

Final: CMS finalized these proposals.

Hospital Inpatient Quality Reporting Program

Proposed: CMS proposed removing seven chart-abstracted measures and one structural measure and adopting five new claims-based measures. It also proposed validating two new chart-abstracted measures — hospital-onset MRSA bacteremia and C. diff — as well as allowing hospitals to electronically submit data for 16 quality measures from four measure sets.

CMS also proposed expanding the collection of CAUTI and CLABSI measures beyond the intensive care unit, including medical, surgical and medical/surgical wards, beginning in January 2014.

Final: CMS finalized the removal of six chart-abstracted measures and one structural measure for FY 2016. It will also suspend one chart-abstracted measure (immunization for pneumonia) it had proposed removing and will adopt the five proposed new measures for FY 2016. It will also validate the two new chart-abstracted measures of MRSA and C. diff. and will allow hospitals to electronically submit data for measures described in the proposal.

CMS decided to delay expanding the CAUTI and CLABSI measures beyond the ICU to January 2015.

Hospital Value-Based Purchasing Program

Proposed: CMS proposed readopting all finalized FY 2015 Clinical Process of Care measures for FY 2016 except primary percutaneous coronary intervention received within 90 minutes of hospital arrival, blood cultures performed in the emergency department prior to initial antibiotic received in hospital and discharge instructions for heart failure patients. CMS also proposed adopting new measures, including influenza immunization, CAUTI and surgical site infection, for FY 2016.

For FY 2016, CMS proposed the following domain weight changes for hospitals receiving a score on all domains: decreasing the clinical process of care domain from 20 percent in FY 2015 to 10 percent, decreasing the patient experience of care domain from 30 percent in FY 2015 to 25 percent, increasing the outcome domain from 30 percent to 40 percent and increasing the efficiency domain from 20 percent to 25 percent. (In FY 2014, the domain weights are 45 percent for clinical process of care, 30 percent for patient experience of care and 25 percent for outcomes, which is a new domain for the program. There is no efficiency domain for FY 2014.)

In addition, CMS proposed a disaster/extraordinary circumstance waiver process under the Hospital VBP program for hospitals struck by a natural disaster or experiencing extraordinary circumstances. CMS proposed requiring exception requests to be made at the same time as waiver requests under the Hospital IQR Program, which are due within 30 days of the extraordinary circumstance.

Final: The final rule readopted the finalized FY 2015 Clinical Process of Care measures and the exceptions proposed, with the two additional exceptions of prophylactic antibiotic received within one hour prior to surgical incision and cardiac surgery patients with controlled 6 a.m. postoperative serum glucose. CMS is also adopting the proposed new measures and new domain weights for FY 2016.

CMS is finalizing the disaster/extraordinary circumstance waiver process with the exception of requiring waiver requests at the same time as waiver requests for the Hospital IQR Program. Instead, waiver requests under the VBP Program will be due within 90 calendar days of the natural disaster or other extraordinary circumstance.  

More Articles on the FY 2014 IPPS Rule:

10 Quality Provisions in the FY 2014 IPPS Rule to Know
CMS Responds to 6 Major Critiques of Readmission Measure
CMS Releases Final Rule on 2014 Inpatient Payments

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