Administrative Memos

200603

FROM: Theodore O. Will, Chief Executive Officer
DATE: Jun 01, 2006
SUBJECT: PROPOSED CHANGES TO THE REPORTING OF HOSPITAL QUALITY DATA FOR ANNUAL PAYMENT UPDATE (RHQDAPU) PROGRAM
IPRO CONTACTS:

Marguerite Shaffer, RN, Senior Director, Intervention Strategies 518-426-3300, ext. 108

The voluntary Hospital Quality Initiative is intended to empower consumers with quality of care information to help them make more informed decisions about their health care while also encouraging hospitals and clinicians to improve the quality of care they provide.

In an effort to share the most up-to-date information pertaining to hospital public reporting for the Hospital Annual Payment Update (APU), IPRO has prepared this summary of the proposed changes.

Currently, hospitals are collecting and reporting data on a "starter set" of 10 clinical measures that have been in use since 2003. New York State has 100% of qualifying acute care hospitals consistently reporting on these measures and over 70% of hospitals reporting on additional measures. Hospitals that do not submit data on the 10 clinical measures and/or do not pass the validation process (80% passing rate) experience an APU reduction of 0.4%.

The Deficit Reduction Act of 2005 requires the Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS) to reduce the APU by 2.0% for hospitals that fail to report the required quality measures. It also requires the Secretary of Health and Human Services to take steps to expand the number of measures to be publicly reported. It calls for further expansion of the measures in 2008 that reflect consensus among affected parties.

CMS has proposed changes to the hospital inpatient prospective payment system for the fiscal year 2007 to comply with the Deficit Reduction Act. Since there is a significant possibility that these rules may be adopted as proposed, it is important that senior administrators in your organization familiarize themselves with the rule and understand its implications for your hospital.

• The number of publicly reportable measures required to obtain the full APU of 3.4% for federal fiscal year 2007 will be expanded from 10 to 21 measures. These 21 quality measures are the Hospital Quality Alliance measures that the Institute of Medicine (IOM) recommended that HHS use as an expanded set for public reporting. Hospitals will be required to submit data on the additional measures to the QIO Clinical Warehouse beginning with discharges that occur in the first calendar quarter of 2006 (January through March). The deadline for hospitals to submit their data, directly or through their quality measure vendors, for first quarter 2006 is August 15, 2006.

• Submission of data for the federal fiscal year 2007 update will be in accordance with the joint CMS/JCAHO sampling requirements located on the QualityNet Exchange Web site. Hospitals will continue to be required to meet chart validation requirements with a minimum of 80% reliability. The procedure for making quality data available to the public after ensuring that a hospital has the opportunity to review, in advance, its data that are to be made public will continue.
• CMS will explore the feasibility of adopting additional measures for the fiscal year 2008 APU, including the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) patient survey results, structural and outcome measures described in the IOM report, and other quality measures that reflect consensus among affected parties.

To view the full Federal Register notice on the proposed hospital reimbursement changes, including the APU and future plans for "pay for performance" as well as many other aspects of hospital reimbursement, download or print the document at the following web link:

Please note that the file is about 50 Megabytes, so it will take some time to download. Much of the proposal relevant to considerations discussed in this memorandum can be located on pages 24091 - 24100 of the above linked document. The full set of the expanded set of 21 measures can be found on p. 24093, and is also reproduced as an attachment to this memo.

Hospitals wishing to take advantage of the comment period may submit comments on the proposed regulation at http://www.cms.hhs.gov/erulemaking. Click on the link "Submit electronic comments on CMS regulations with an open comment period." On the next page that appears click on the link: "CMS-1488-P; Proposed Changes to the Hospital Inpatient Prospective Payment Systems and Fiscal Year 2007 Rates". Please include the caption, "Hospital Quality Data," at the beginning of your comment. The public comment period closes at 5 p.m. on June 12, 2006.

If you should have any questions regarding this memorandum, please contact Marguerite Shaffer at 518-426-3300, ext. 108.