Proposed Quality Data Reporting Changes

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The Centers for Medicare & Medicaid Services (CMS) released a proposed rule to update the hospital inpatient prospective payment system and long-term care hospital (LTCH) prospective payment system (PPS) for federal fiscal year 2018. The proposed rule was published in the Federal Register on April 28, 2017. Here’s a look at some proposed changes in Section IX of the proposed rule regarding quality data reporting requirements.

Hospital Inpatient Quality Reporting (IQR) Program

The proposed rule calls for refinement of current measures and introduction of new ones.

There are proposed changes to the IQR program’s Extraordinary Circumstances Extensions/Exemptions (ECE) policy to align with other CMS quality programs. An ECE request is for an extension or exemption from various quality reporting due to circumstances beyond the facility’s control. Proposed changes include changing the policy’s name from ECE to extraordinary circumstances exceptions beginning October 1, 2017. In addition, CMS clarifies in the proposed rule that it will strive to respond to ECE requests within 90 days of the request’s receipt.

PPS-Exempt Cancer Hospital Quality Reporting (PCHQR) Program

To improve quality of care for the populations served by PPS-exempt cancer hospitals, the proposed rule includes new measures for quality reporting.

The PCHQR program includes several criteria for determining when a measure should be retained or removed from the program.

LTCH Quality Reporting Program (QRP)

The LTCH QRP currently has 17 finalized measures. For fiscal year (FY) 2020, CMS proposes changes to measures for skin integrity. The proposed rule also includes these new measures to be reported for FY 2020:

  • Changes in skin integrity post-acute care: pressure ulcer/injury
  • Compliance with spontaneous breathing trial by day two of the LTCH
  • Ventilator liberation rate

Along with skilled nursing facilities, inpatient rehabilitation facilities and home health agencies, LTCHs are required to report standardized patient assessment data in these five categories for FY 2019:

  • Functional status
  • Cognitive function
  • Special services, treatments and interventions
  • Medical treatments and comorbidities
  • Impairments

Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program

The IPFQR program currently has 18 finalized measures. For FY 2020, the proposed rule includes one new measure for medication continuation.

Clinical Quality Measurement for Eligible Hospitals & Critical Access Hospitals (CAH) Participating in the Electronic Health Record (EHR) Incentive Programs

The Clinical Quality Measurement includes incentive payments with Medicare and Medicaid for adoption and meaningful use of certified EHR technology (CEHRT) by reporting of clinical quality measures (CQM) or electronic CQMs.

For calendar year (CY) 2017, if a hospital or CAH is demonstrating meaningful use for the first time or any time in 2017, the reporting period is two self-selected quarters of CQM data in CY 2017. If a hospital or CAH only is participating in the EHR Incentive Program or both the EHR Incentive hospital IQR programs, the hospital can report on at least six self-selected available CQMs instead of eight.

Clinical Quality Measurement for Eligible Professionals (EP) Participating in the Medicaid EHR Incentive Program

For eligible professionals participating in the EHR Incentive Program, CMS is proposing to modify the CQM reporting period to a minimum of a continuous 90-day period during the calendar year. CMS also is proposing to align the specific CQMs available to EPs participating in the Medicaid EHR Incentive Program to those in the Merit-Based Incentive Payment System (MIPS). This is occurring because CMS has observed alignment between CQMs selected for the Medicaid and Medicare EHR Incentive Programs for EPs and the electronic measures selected for the Physician Quality Reporting System program.

For CY 2017, eligible providers can report on any six CQMs relevant to their scope of practice, allowing providers greater flexibility in selecting CQMs to report and assuring they can report on the same CQMs from their EHR to both MIPS and the Medicaid EHR Incentive Program.

Changes to the Medicare & Medicaid EHR Incentive Program

In CY 2018, the EHR reporting period will be updated from a full year to a minimum of any continuous 90-day period within CY 2018. Eligible providers and hospitals that directly attest to a state for the state’s Medicaid EHR Incentive Program would attest to meaningful use of CEHRT for an EHR reporting period of a minimum of any continuous 90-day period from January 1, 2018, to December 31, 2018. All other related program requirements would remain the same.

Read the entire Section IX: Quality Data Reporting Requirements for Specific Providers and Suppliers here.

Contact your BKD advisor if you have questions.

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