Eloquest Healthcare is excited to welcome back Jo Ann Brooks PhD, RN, FAAN, FCCP to the Eloquest Healthcare Blog! Dr. Jo Ann Brooks is a Healthcare Quality Consultant who retired in 2018 from Indiana University Health where she was System Vice President of Quality & Safety. In this role, she was responsible for oversight of quality and patient safety in a multi-hospital, integrated system as well as infection prevention across the state. Her areas of oversight included performance improvement, external quality reporting, patient safety, national databases, and ongoing development of the governance board’s role in quality and patient safety.
In Jo Ann’s consulting role, she lectures and consults on healthcare quality and safety, CMS pay for performance, non-ventilator hospital-acquired pneumonia and sustainability in quality improvement. Jo Ann also currently serves as the Chair of IRB 04 for Indiana University. Her faculty appointments include IU Schools of Nursing and Medicine and Purdue University School of Nursing.
The focus on quality has taken a backseat during the COVID-19 pandemic. It is understandable as hospitals and systems are continuing to deal with the pandemic as well as staffing crises and increases in hospital expenses for drugs, labor, and supplies. So 10 years after the launch of the Centers for Medicare and Medicaid Services (CMS) pay for performance programs, where are these programs headed in 2023?
The final FY2023 (October 1, 2022-September 30, 2023) Inpatient Prospective Payment System (IPPS)/Long Term Care Hospital Prospective Payment Rule was posted on August 1, 2022.1 In summary, the rule updates Medicare payment policies and quality reporting programs relevant to inpatient hospitals. New initiatives include building key priorities to address health disparities and to improve the safety and quality of maternity care.2 For the Inpatient Quality Reporting program (IQR) which is pay for reporting, ten new measures were finalized (examples include a measure that access a hospital’s commitment to equity, one related to opioid-related events and one that captures screening for determinants of health) as well as refinement of two measures and changes in the existing electronic clinical quality measures (eCQM) reporting.2 In response to the pandemic’s continued impact on hospitals, CMS will continue to waive penalties and modify or suppress measures and measure calculations for certain quality programs.
This article will highlight some of the changes in the three major CMS acute care hospital quality reporting programs which focus on pay for performance: hospital value-based purchasing (HVBP), hospital readmission reduction program (HRRP) and the hospital-acquired condition penalty program (HAC).
CMS will suppress the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) measure and the five Hospital Acquired Infection (HAI) measures all which are impacted by COVID-19. Suppression of these measures will greatly impact the HVBP total performance score as over half of the measures are suppressed. CMS will revise the HVBP methodology such that hospitals will not receive a total performance score for FY2023 and will receive the payment amount that would normally be withheld for HVBP (2%). In addition, there are some technical updates for measures beginning in FY2023 and FY2024 that relate to the Clinical Outcomes Domain and added covariates that adjust for history of COVID-19 diagnosis. The 30-day mortality measure for pneumonia was previously suppressed for FY2023 in the FY2022 rule.
CMS will resume the use of the pneumonia 30-day readmission measure in FY2024 (was previously suppressed in FY2023 rule). Also, covariate adjustments for history of COVID-19 will be applied to all six condition/procedure specific readmission measures.
Hospitals will not incur penalties for the HAC program in FY2023. The CMS Patient Safety Indicator (PSI) 90 composite measure and the five HAIs measures will be suppressed in FY2023 thus no HAC score will be calculated. However, CMS will publicly report the PSI 90 composite measure results to be transparent about patient safety.3 Two technical measure updates for PSI 90 include COVID-19 risk adjustment beginning in FY2024 and a minimum volume threshold to receive a PSI composite score.
CMS received public comments on potential future consideration of two HAI measures for the Hospital Inpatient Quality Reporting Program, the HAC program, HVBP program and Prospective Payment System Exempt Cancer Hospital Quality Reporting program (PCHQR): National Health-care Safety Network (NHSN) Health-care associated Clostridioides difficile infection outcome measure and NHSN Hospital-onset bacteremia and fungemia outcome measure.
In summary, there are no major changes in the FY2023 pay for performance programs compared to FY2022 as we continue to slowly recover from the pandemic. Unfortunately, it will probably be a few years before these programs are again fully functional to provide meaningful data and help to promote quality of care through financial incentives.
Download this FREE resource to understand the financial implications of hospital-acquired conditions established in the Affordable Care Act (ACA).
Hear more from Dr. Jo Ann Brooks
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- FY2023 Inpatient Prospective Payment System (IPPS)/Long Term Care Hospital Prospective Payment Rule. https://public-inspection.federalregister.gov/2022-16472.pdf Released August 1, 2022.
- Centers for Medicare and Medicaid Services. FY2023 IPPS/LTCH PPS Proposed Rule Overview for Hospital Quality Programs. Webinar. May 18, 2022. https://www.qualityreportingcenter.com/en/inpatient-quality-reporting-programs/hospital-inpatient-quality-reporting-iqr-program/2022-events/iqr51822/
- CMS issues hospital IPPS final rule for FY 2023. https://www.aha.org/news/headline/2022-08-02-cms-issues-hospital-ipps-final-rule-fy-2023 August 2, 2022.