On April 23 the Centers for Medicare & Medicaid Services (CMS) released the Proposed Rule and Request for Information for both the FY 2020 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Acute Care Hospital (LTCH) Prospective Payment System (PPS). Among the annual changes to the payment rates and existing quality programs, CMS puts forth an array of specific proposed policies directed at initiatives in both IPPS and LTCH PPS.
Medicare and Medicaid Promoting Interoperability Programs
CMS is proposing an EHR reporting period of a minimum of any continuous 90-day period in calendar year (CY) 2021 for new and returning participants in the Medicare Promoting Interoperability Program attesting to CMS. Additionally, CMS is proposing to continue the Query of Prescription Drug Monitoring Program (PDMP) measure as optional and available for bonus points. In addition, CMS is proposing to remove the Verify Opioid Treatment Agreement measure.
As it relates to this program, CMS also seeks comment on the following topics:
- Opioid measures based on existing efforts by the National Quality Forum (NQF) and the Centers for Disease Control and Prevention (CDC) for potential inclusion in the Promoting Interoperability Program
- Measures to engage vendors and clinicians in improving the efficiency of providers’ use of EHRs
- Inclusion of Medicare Promoting Interoperability Program data on the CMS Hospital Compare website
- Integration of Patient-Generated Health Data into EHRs using CEHRT
- Activities that promote the safety of the EHR
- Measure requiring the use of an open application programming interface (API), including reporting of such a measure as an alternative to the patient access measure
Inpatient Quality Reporting Program Requirements
CY’s 2020 and 2021 will have the same number of measures reported for the same length of time as the current Inpatient Quality Reporting Program requirements.
- Eligible hospitals must report four eCQMs or face a negative IQR payment adjustment.
- Promoting Interoperability has the same requirements as IQR unless the Eligible Hospital meets the exemption criteria.
- Eligible Hospitals must capture four eCQMs for one quarter of the calendar year.
- Eligible Hospitals and Critical Access Hospitals must use 2015 CEHRT and the most recent eCQM specifications to capture eCQMs.
- Eligible Hospitals and Critical Access Hospitals must report eCQMs to QualityNet using QRDA1 by February 28, 2021, for CY 2020 reporting.
- Eligible Hospitals which can’t report electronically are allowed to attest all 16 eCQMs for the full year to the Promoting Interoperability Program. Attesting Eligible Hospitals will still receive a negative IQR adjustment.Medicaid hospitals will need to meet state reporting requirements.
- The hybrid all-cause readmission measure (and two new eCQMs around opioids) will be added to the menu measure set for CY 2020.
In CY 2022, CMS is proposing the following changes:
- Reporting would change from 90 days to one self-selected quarter of data.
- Eligible Hospitals must report three self-selected eCQMs from the menu set and all EHs must report on the proposed Safe Use of Opioids – Concurrent Prescribing eCQM.
- Eligible Hospitals must still use the latest CEHRT (2015) updated with the latest eCQM specifications leveraging the QRDA I standard and CMS QRDA implementation guide.
- Eligible Hospitals will have two years to voluntarily report the Hybrid Hospital-Wide All-Cause Readmission measure. Then, CMS is proposing a data capture period which will run from July 1, 2023-June 30, 2024.
“Rethinking Rural Health”
In this proposed rule, CMS hones in on plans that are designed to better guarantee that people living in rural America have access to high quality, affordable healthcare. This component of the proposed rule looks at addressing wage index disparities and adjusting the calculations of hospitals below the 25th percentile and those above the 75th percentile so that Medicare spending does not increase as a result of this proposal.
CMS also dives into the topic of a new technology add-on payment pathway for devices. This proposal is an effort to address existing Food and Drug Administration (FDA) programs that can help expedite the development and review of new drugs and devices. The proposed rule as well as the official CMS fact sheet provide further detail on the proposed calculation, potential revisions to the New Technology Add-On Payment Substantial Clinical Improvement Criterion, and Applications for New Technology Add-on Payments for FY 2020.
LTCH Quality Reporting Program
In regards to this program, CMS is proposing to adopt two new quality measures in the quality measure domain of the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act) on transferring health information as well as a number of standardized patient assessment data elements that assess functional status, cognitive function and mental status, special services, treatments and interventions, medical conditions and comorbidities, impairments, or social determinants of health. In response, CMS is proposing to modify the previously adopted Discharge to Community measure to exclude nursing home residents who already reside in the nursing home, move the implementation date of future versions of the LTCH CARE Data Set from April to October, adopt data collection and public display periods for various measures, and no longer publish a list of compliant LTCHs on the LTCH QRP website.
Comments are due on June 24, 2019. HIMSS is currently in the process of reviewing these proposed policies in further detail and preparing a comment letter.