The Centers for Medicare & Medicaid Services issued a proposed rule yesterday that would update payment policies and rates under the End-Stage Renal Disease Prospective Payment System and propose changes to the ESRD Quality Incentive Program for payment year 2017 and PY 2018.
ESRD QIP changes
A new reporting measure that will capture hospital readmissions data and removal of hemoglobin as a measurable indicator are part of the proposed QIP for next year. There will be eight clinical measures and three reporting measures, encompassing anemia management, dialysis adequacy, vascular access type, patient experience of care, infections, hospital readmissions, and mineral metabolism management. Five of the proposed PY 2017 clinical measures would be captured in two clinical measure “topics” or categories (Kt/V Dialysis Adequacy and Vascular Access Type). Aside from the newly proposed Standardized Readmission Ratio (SRR) measure, CMS is proposing to revise the National Healthcare Safety Network (NHSN) Bloodstream Infection in Hemodialysis Outpatients measure to calculate facility performance using the Adjusted Ranking Metric. CMS is not proposing to make any changes to the Hypercalcemia measure or to the measures in the Kt/V Dialysis Adequacy measure topic or Vascular Access Type measure topic. The rule also proposes to remove the Hemoglobin Greater than 12 clinical measure because the measure is “topped out,” CMS said.
The three proposed reporting measures include the In-Center Hemodialysis Consumer Assessment of Healthcare Providers and Systems (ICH CAHPS), Anemia Management, and Mineral Metabolism. CMS is not proposing to make any changes to the specifications for the Anemia Management and Mineral Metabolism reporting measures, and it is not proposing any changes to the way the three reporting measures are scored. However, the agency is proposing that dialysis facilities will no longer have the option to attest that they only had one qualifying case to avoid being scored on the reporting measures.
Proposed changes for PY 2018
The agency is anticipating more significant changes in payment year 2018, proposing the QIP measure set (applicable for performance year 2016) will contain eleven clinical measures and five reporting measures encompassing anemia management, dialysis adequacy, vascular access type, patient experience of care, infections, mineral metabolism management, safety, pain management, depression management, and hospital readmissions. This represents an evolution of the program that encompasses quality-of-care issues.
In an effort to align the ESRD QIP with other Value-Based Purchasing and quality reporting initiatives, CMS said it is proposing to re-organize the clinical measures into a Clinical Measure-Domain with component subdomains tracking to the CMS Quality Strategy.
The proposed Safety subdomain, accounting for 20% of the Clinical Measure Domain score, would include the NHSN Bloodstream Infection in Hemodialysis Outpatients measure.
The proposed Patient and Family Engagement/Care Coordination subdomain, accounting for 30% of the Clinical Measure Domain score, would include the ICH CAHPS measure and the Standard Readmission Ratio measure.
The proposed Clinical Care subdomain, accounting for 50% of the Clinical Measure Domain score, would include the Standard Transfusion Ratio (STrR) measure, the Kt/V Dialysis Adequacy measure topic, the Vascular Access Type measure topic, and the Hypercalcemia measure.
New clinical measures proposed for PY 2018 include ICH CAHPS (converted from a previous reporting measure), STrR, and Pediatric Peritoneal Dialysis (part of the Kt/V Dialysis Adequacy measure topic).
The rule for PY 2018 proposes to adopt five reporting measures. CMS is proposing to continue using the Anemia Management reporting measure, but is proposing to revise the Mineral Metabolism measure revised to allow facilities to submit serum and plasma phosphorus data. CMS is also proposing to adopt three new reporting measures, which are Pain Assessment and Follow-Up, Clinical Depression Screening and Follow-Up, and NHSN Healthcare Personnel Influenza Vaccination.
Under the proposed rule, reporting measure scores would be totaled for the facility’s Reporting Measure Domain score. CMS would then calculate the dialysis facility’s Reporting Measure Adjuster by subtracting the facility’s Reporting Measure Domain score (i.e., the sum of all reporting measure points received) from its total eligible reporting measure points (e.g., 50, if the dialysis facility is eligible for all five reporting measures), and then multiplying that total by a coefficient of 5/6. CMS proposes to calculate a facility’s total performance score by subtracting the facility’s Reporting Measure Adjuster from its Clinical Measure Domain score.
CMS will accept comments on the proposed rule until September 2, 2014.
The proposed rule will appear in the July 11, 2014 Federal Register and can be downloaded from the Federal Register at: http://www.ofr.gov/inspection.aspx?AspxAutoDetectCookieSupport=1.