CMS Proposes Hospital Payment and Quality Changes in IPPS Proposed FY2023 Rule

The Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the fiscal year 2023 prospective inpatient payment system (IPPS) on April 18. The AAMC will provide comments to the CMS, which are expected from here on June 17th. to the hospital payment and quality provisions detailed below, the rule contains two GME proposals for full-time equivalent weighted caps and 1-2 rural training programs [refer to related story].

The proposed rule includes the following key points regarding hospital payment and quality:

Payment proposals:

IPPS Payments Update for FY 2023

CMS has proposed to increase operating payment rates by 3.2% for general acute care hospitals paid under IPPS that successfully participate in the Inpatient Quality Reporting (IQR) program and are significant users of electronic health records (EHRs). This reflects the projected hospital consumption basket update of 3.1%, reduced by a productivity adjustment of 0.4 percentage points and increased by 0.5 percentage points for a documentation adjustment and coding required by law. The proposed increase in operating and capital IPPS payment rates, partially offset by the decrease in outlier payments for extremely expensive cases, will generally increase hospital payments in fiscal year 2023 by $1.6 billion. .

Medicare Disproportionate Share Hospital (DSH) and Unpaid Care Payments

CMS proposed to distribute approximately $6.5 billion in unpaid care payments for fiscal year 2023, a decrease of approximately $654 million from fiscal year 2022. CMS would use the last two years of verified data from the S-10 spreadsheet, fiscal year 2018 and fiscal year 2019, distribute these funds. Beginning in FY2024, CMS proposed to use a three-year rolling average of verified data from the S-10 worksheet. CMS predicts this will be the first year that three years of verified data will be available. Beginning in fiscal year 2023, CMS will discontinue using insured low-income days as a proxy indicator of unpaid care payments for Indian Health Service and Tribal Hospitals and hospitals located in Puerto Rico; instead, the CMS proposed to establish a new additional payment for these hospitals.

Medicaid portion

CMS has proposed to change the calculation of the Medicaid fraction of the DSH calculation by revising the definition of patients “deemed eligible for Medicaid” to only include patients who receive health insurance through a demonstration of Section 1115 itself. or who purchase such insurance with the use of premium support authorized as part of an 1115 demonstration.

New Technology Complementary Payment (NTAP)

CMS has proposed that beginning in FY2024, full applications for NTAP will be posted online. CMS also proposed using national drug codes instead of ICD-10-PCS Section “X” codes to identify cases involving the use of approved therapeutic agents for NTAPs from a transition period during the 2023 financial year.

Salary index

The CMS proposed to continue the policy of indexing low salaries in the 2023 financial year in a budget-neutral way by applying an adjustment to the standardized amount. Beginning in FY 2023 and beyond, CMS has proposed to apply a 5% cap on any decrease in a hospital’s salary index from its salary index in the fiscal year. precedent, regardless of the circumstances causing the decline.

Data Reporting Standards for COVID-19 and Seasonal Influenza

As part of the conditions of participation, the CMS has proposed requiring hospitals, including critical access hospitals (CAHs), to continue to report COVID-19 and seasonal influenza after the emergency ends. public health (PHE) COVID-19. From the end of the current COVID-19 PHE statement or the effective date of the IPPS proposed rule, whichever is later, until April 30, 2024, a hospital or a CAH must electronically transmit COVID-19 and seasonal influenza information daily in a standardized format specified by the secretary. In addition, CMS proposed to establish a framework for future reporting in the event of another PHE based on the National Healthcare Safety Network, as this is a vendor-neutral federal system that can accept data submissions from a variety of non-governmental entities. .

Quality Proposals:

Changes to pay-for-performance programs

The proposed rule would remove penalties under the Hospital Ailment Reduction Program (HACRP) and apply a neutral payment adjustment under the hospital value-based purchase program for fiscal year 2023 due to proposed removal of measures in programs to address the ongoing impacts of COVID -19 PHE. The CMS proposed an updated risk adjustment for HACRP to account for the diagnosis of COVID-19 in the PSI-90 measure, to publicly and confidentially report the results of the nosocomial infections measure (but not to report the PSI-90 measure for fiscal year 2023), and remove the nosocomial infection measure data for calendar year (CA) 2021 from fiscal year 2024. It was also proposed to include a covariate adjustment for patient’s history of COVID-19 in the year prior to admission indexed for all readmission measures in the hospital readmission department. Reduction in Harm Reduction Program (HRRP) from FY23, resumption of pneumonia readmission measure in FY24, and request for feedback on how to update scoring HRRP to encourage hospitals to improve their performance for socially at risk populations.

Addressing Health Equity

Three new equity-specific quality measures for the IQR program have been proposed: hospital commitment to health equity, screening for social factors of health, and positive screening rate for social factors of health. health. The first measure would begin with mandatory reporting from CY 2023, while screening measures would begin with voluntary reporting from CY 2023 before making reporting of each measure mandatory in CY 2024. Maternal health was addressed through the adoption of a new “birth-friendly” hospital designation. [refer to Washington Highlights, April 15] and two new maternal health measures for the IQR: the Electronic Cesarean Section Clinical Quality Measure (eCQM) and the eCQM of Serious Obstetric Complications; each would start with voluntary reporting for CY 2023, followed by mandatory reporting from CY 2024. Finally, the agency is soliciting feedback through two Requests for Information (RFIs) – one specific to the assessing the impact of climate change on health equity and the other regarding a cross-cutting framework for assessing health care quality disparities among Medicare quality programs.

Other Changes to the IQR Program

Five new measures were proposed in addition to the equity-focused measures mentioned above, as well as the refinement of two other existing measures. The proposals also included changes to reporting requirements for eCQMs and hybrid metrics, including increasing the total number of eCQMs hospitals must report from CY 2024 reporting and requiring 100% completeness. for requests for medical files for the validation of the eCQM declaration from the validation of the data declared CY 2022 (impacting the payment for the 2025 financial year). CMS has also proposed new data submission and reporting requirements for patient-reported, outcome-based performance measures for the future.

Medicare Interoperability Promotion Program (“Meaningful Use”)

The CMS has proposed changes to the scoring methodology starting with the EHR reporting period CY 2023, including starting to require hospitals to report the Prescriptive Drug Monitoring Program measure. The addition of a new optional measure has been introduced, the activation of the exchange within the framework of the exchange of trust and common agreement (TEFCA) within the framework of the exchange objective of information for EHR CY 2023 reports. A new measure of antibiotic use and antibiotic resistance has also been added as a required measure under the clinical data exchange objective and public health as of EHR reporting CY 2023 and consolidation options to report active engagement under the goal. Finally, it was also proposed to make some program data public from the EHR reporting period CY 2023 and adopt the additions of IQR eCQM metrics and reporting requirements for alignment between the two programs.

RFI on Using Health IT to Improve Quality Measurement and Reporting

The First RFI expanded on last year’s RFI regarding the advancement of digital quality measurement and the use of Rapid Healthcare Interoperability Resources (more commonly known as FHIR) in hospital quality programs . The second RFI is specific to the advancement of TEFCA.

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