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.
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:
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.
In CY 2022, CMS is proposing the following changes:
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.
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.