Q-Centrix Comments on CMS’ Inpatient Prospective Payment System Proposed Rule
PORTSMOUTH, N.H. (June 16, 2015) – The Centers for Medicare & Medicaid Services (CMS) proposed a new rule regarding the fiscal year 2016 hospital Inpatient Prospective Payment Systems (IPPS) in April. Comments on the proposed rule were accepted by CMS until June 16, 2015. As a leader in the quality data abstraction market servicing more than 300 partner hospitals and employing nearly 700 nurse-educated, quality information specialists, Q-Centrix provided written comment to CMS.
“Our concern is the proposed sequencing of removing manual measures and replacing them with eCQM will create a national ‘gap period’ of several years where quality standards will retreat,” explains Milton Silva-Craig, Q-Centrix CEO. “Simultaneously removing the gold standard of quality measurements, manual data abstraction, and replacing it with a currently immature technology, eCQM, will yield poor quality performance. It is our impression that this unintended consequence contradicts the very nature of the quality movement in healthcare.”
The Proposed Rule:
On April 17, 2015 CMS issued a proposed rule which would apply to approximately 3,400 acute care hospitals and approximately 435 long-term care hospitals. The changes would affect discharges occurring on or after October 1, 2015. CMS is proposing to update the measures used in the Hospital Inpatient Quality Reporting (IQR) Program. The rule proposes to add a total of eight new measures for the FY 2018 payment determination and subsequent years, remove nine measures, two of which are suspended, as well as refine two previously adopted measures to expand measure cohorts.
Also, CMS proposes to require each hospital to submit 16 from the 28 available inpatient eCQMs covering three National Quality Strategy domains beginning in calendar year (CY) 2016 for the FY 2018 payment determination. This will align the Hospital IQR Program with the Medicare Electronic Health Record Incentive Program for eligible and critical access hospitals. CMS also proposes to require two quarters (Q3 and Q4) of reporting in CY 2016.
The Q-Centrix Comment:
Q-Centrix fully endorses CMS’ use and reporting of quality measures and continues to support evolution towards electronic reporting of quality measures (eCQM). The purpose of its comment on the proposed rule is to avoid the potential for quality standards to suffer during the transition period from manual abstraction to eCQM, if the rule is implemented as proposed.
“After more than 30 years of refining core measures in order to arrive at the gold standard for hospital quality measurement, the rule removes and replaces the measures with eCQMs,” explains Silva-Craig. “eCQMs are, today, an immature technology with no current quality threshold requirements.”
In its full letter, Q-Centrix explains hospitals are staffed with personnel experienced, trained, and efficient in the manually-abstracted measure process. Q-Centrix recommends continued reporting of manually-abstracted measures in parallel with eCQMs. The simultaneous expansion of the eCQM pilot process, using manually-abstracted measures as a control, allows for evidence-based comparison data.
Q-Centrix points to several factors that contribute to the difficulty of consistent, accurate reporting of eCQMs, including the lack of full data integration across hospital EHRs and ancillary information systems required to capture the necessary data elements for quality reporting. To read the entire letter, visit q-centrix.com/proposedrule.
Q-Centrix aims to improve patient safety in the U.S. through the use of market-leading technology coupled with the industry’s largest and broadest team of nurse-educated, quality information specialists. Conducting in excess of one million quality data abstractions annually, Q-Centrix is a comprehensive quality partner to its hundreds of hospitals, providing clinical surveillance, abstraction, analysis and improvement solutions.
To learn more about the leader in clinical surveillance and quality data abstraction technology-enabled solutions, visit q-centrix.com.