CMS Proposed Rule Shifts Public Health, Quality Measurement Reporting Requirements
On April 27, officials at the federal Centers for Medicare and Medicaid Services (CMS) announced that the agency was planning to expand the requirements for hospitals and critical access hospitals to expand data reporting in order to better respond to the impact of the COVID-19 pandemic.
In a press released on Tuesday, the agency, after announcing a “proposed rule would fund medical residency positions in hospitals in rural and underserved communities to address workforce shortages, and require hospitals to report COVID-19 vaccination rates among their workers,” further announced a proposed change to data reporting.
“In addition,” the Fact Sheet notes, “the proposed rule seeks to strengthen the ongoing response to the public health emergency and future health threats by leveraging meaningful measures for quality programs. CMS is proposing the adoption of the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure to require hospitals to report COVID-19 vaccinations of workers in their facilities. This proposed measure is designed to assess whether hospitals are taking steps to limit the spread of COVID-19 among their workforce, reduce the risk of transmission within their facilities, help sustain the ability of hospitals to continue serving their communities through the public health emergency, and assess the nation’s long-term recovery and readiness efforts.
Additionally, CMS is proposing to modify the Promoting Interoperability program requirements for eligible hospitals and critical access hospitals to expand reporting within the Public Health and Clinical Data Exchange Objective. The proposal would require hospitals to report on all four of the following measures: Syndromic Surveillance Reporting, Immunization Registry Reporting, Electronic Case Reporting, and Electronic Reportable Laboratory Result Reporting.
Requiring hospitals to report these four measures would help to prepare public health agencies to respond to future health threats and a long-term COVID-19 recovery by strengthening public health functions, including early warning surveillance, case surveillance, and vaccine uptake which will increase the information available to help hospitals better serve their patients. Requiring these measures would enable nationwide syndromic surveillance for early warning of emerging outbreaks and threats; automated case and laboratory reporting for rapid public health response; and local and national visibility on immunization uptake so public health can tailor vaccine distribution strategies.”
Meanwhile, the same proposed rule includes the following elements, per the Fact Sheet on the proposed rule:
“Repeal of the Market-Based MS-DRG Relative Weight Policy
CMS is proposing to repeal the requirement that a hospital report on the Medicare cost report the median payer-specific negotiated charge that the hospital has negotiated with all of its MA organization payers, by MS-DRG, for cost reporting periods ending on or after January 1, 2021. CMS estimates this will reduce administrative burden on hospitals by approximately 64,000 hours. We are also proposing to repeal the market-based MS-DRG relative weight methodology that was adopted effective for FY 2024, and to continue using the existing cost-based MS-DRG relative weight methodology to set Medicare payment rates for inpatient stays for FY 2024 and subsequent fiscal years.
Future of Digital Quality Measurement
CMS is seeking comment on plans to modernize its quality measurement enterprise:
Ø Clarifying the definition of digital quality measures;
Ø Using the Fast Healthcare Interoperability Resources (FHIR®) standard for eCQMs that are currently in the various quality programs;
Ø Standardizing data required for quality measures for collection via FHIR-based Application Programming Interfaces (APIs);
Ø Leveraging technological opportunities to facilitate digital quality measurement;
Ø Better supporting data aggregation;
Ø Developing a common portfolio of measures for potential alignment across CMS regulated programs, federal programs and agencies, and the private sector.
Hospital Inpatient Quality-Reporting (IQR) Program
The Hospital IQR Program is a pay-for-reporting quality program that reduces payment to hospitals that fail to meet program requirements. Hospitals that do not submit quality data or fail to meet all Hospital IQR Program requirements are subject to a one-fourth reduction in their Annual Payment Update under the IPPS. In the FY 2022 IPPS/LTCH PPS proposed rule, CMS is proposing to adopt five new measures, remove five existing measures, and make changes to the existing EHR certification requirements along with other administrative updates. CMS is also requesting comment on the potential future adoption of a COVID-19 mortality measure and patient reported outcome measure following elective primary total hip and/or knee arthroplasty.
Specifically, the rule proposes to adopt:
Ø A new structural measure—Maternal Morbidity Structural Measure—beginning with a shortened CY 2021 reporting period/FY 2023 payment determination;
Ø The COVID-19 Vaccination Coverage Among Health Care Personnel (HCP) measure beginning with a shortened reporting period from October 1, 2021 through December 31, 2021, affecting the CY 2021 reporting period/FY 2023 payment determination and for subsequent years;
Ø Hybrid Hospital-Wide All-Cause Risk Standardized Mortality (Hybrid HWM) measure in a stepwise fashion, beginning with a voluntary reporting period which will run from July 1, 2022 through June 30, 2023, and followed by mandatory reporting beginning with the reporting period which runs July 1, 2023 through June 30, 2024, affecting the FY 2026 payment determination and for subsequent years;
Ø Two medication-related adverse event electronic clinical quality measures (eCQMs) (Hospital Harm-Severe Hypoglycemia eCQM (NQF #3503e) and Hospital Harm-Severe Hyperglycemia eCQM (NQF #3533e)) beginning with the CY 2023 reporting period/FY 2025 payment determination.”
