Summary of 2022 IPPS Proposed Rule: Part Two

Today's article is a continuation of last week's treatment of Medicare's 2022 Inpatient Prospective Payment System Proposed Rule (PR), released in late April. As we pointed out previously, the PR contains over 1,900 pages of proposals. Consequently, we have found it necessary to break down the proposed changes among multiple alerts so that we might provide as many relevant highlights as possible to our readers. With that said, the following will act to summarize more details in the PR—beyond what we summarized last week—that hospital executives and clinicians will find most relevant.

Graduate Medical Education

Section 126 of the 2021 Consolidated Appropriations Act (CAA) requires the distribution of an additional 1,000 new Medicare-funded medical residency positions to train physicians. CMS is proposing to distribute these positions to qualifying hospitals, including those located in rural areas and those serving areas with a shortage of health care professionals. Slots will be phased in at a maximum of 200 per year, beginning in 2023. The Centers for Medicare and Medicaid Services (CMS) is proposing to prioritize applications from qualifying hospitals that serve geographic areas and underserved populations with the greatest need.

The government recognizes that some hospitals hosted medical resident "rotators" for short durations in the past. Due to this rotation system, some hospitals inadvertently missed out on Medicare funding for residents in a new training program. The 2022 PR would restore the hospital's ability to receive such funding if the hospital begins a new medical residency-training program within the first five years after enactment.

Uncompensated Care Payments

The government is proposing to distribute roughly $7.6 billion in uncompensated care payments for FY 2022, which represents a decrease of approximately $660 million from FY 2021. This total uncompensated care payment amount is based, in part, on the estimated impact of the COVID pandemic. CMS will use a single year of data on uncompensated care costs from Worksheet S-10 of hospitals' FY 2018 cost reports to distribute these funds. There will be some divergence relative to the formula used for special facilities, such as tribal health centers.

Quality Measures

To reiterate a word or warning, hospitals that do not submit quality data or fail to meet all Hospital IQR Program requirements will face a one-fourth reduction in their annual payment update under the IPPS. With that in mind, it is important to note that the 2022 PR recommends the following changes to the CMS quality measures for inpatient hospital reporting purposes:

New Measures Added

· A new structural measure—Maternal Morbidity Structural Measure—beginning with a shortened CY 2021 reporting period/FY 2023 payment determination.

· The COVID-19 Vaccination Coverage Among Health Care Personnel (HCP) measure beginning with a shortened reporting period from October 1, 2021 through December 31, 2021, affecting the CY 2021 reporting period/FY 2023 payment determination and for subsequent years.

· Hybrid Hospital-Wide All-Cause Risk Standardized Mortality (Hybrid HWM) measure in a stepwise fashion, beginning with a voluntary reporting period which will run from July 1, 2022 through June 30, 2023, and followed by mandatory reporting beginning with the reporting period which runs July 1, 2023 through June 30, 2024, affecting the FY 2026 payment determination and for subsequent years. The Hybrid HWM measure captures more conditions or procedures than CMS PSI-04. This measure also captures mortality within 30 days of hospital admission for most conditions or procedures, compared to deaths for surgical discharges (or pregnancy, childbirth, and puerperium) as measured by CMS PSI-04.

· Two medication-related adverse event electronic clinical quality measures (eCQMs) (Hospital Harm-Severe Hypoglycemia eCQM (NQF #3503e) and Hospital Harm-Severe Hyperglycemia eCQM (NQF #3533e)) beginning with the CY 2023 reporting period/FY 2025 payment determination.

Current Measures Deleted

· The Death Among Surgical Inpatients with Serious Treatable Complications measure (NQF #0351) beginning with the FY 2023 payment determination. CMS is proposing to remove this measure because it is also proposing a more broadly applicable measure, Hospital HWM, for adoption in this proposed rule.

· The Exclusive Breast Milk Feeding (NQF #0480) measure beginning with the FY 2026 payment determination. CMS is proposing to remove this measure because of the availability of the new Maternal Morbidity Structural measure.

· The Admit Decision Time to Emergency Department (ED) Departure Time for Admitted Patients (NQF #0497) measure beginning with the CY 2024 reporting period/FY 2026 payment determination. CMS wants to remove this measure because the costs associated with it outweigh the benefit of its continued use in the program.

· The two stroke-related eCQMs—Anticoagulation Therapy for Atrial Fibrillation/Flutter eCQM (STK-03) (NQF #0436) and Discharged on Statin Medication eCQM (STK-06) (NQF #0439)—beginning with the CY 2024 reporting period/FY 2026 payment determination. While CMS continues to believe that ensuring appropriate pharmacotherapy for stroke patients is an important topic, within the eCQM portfolio of stroke measures, CMS identified STK 03 and STK-06 as candidates for removal.

Additionally, beginning with the CY 2023 reporting period (FY 2025 payment determination), CMS is proposing to require hospitals to use certified technology that is consistent with the 2015 Edition Cures Update. CMS is also clarifying that certified technology must support the reporting requirements for all available eCQMs.

----------

We anticipate having a final installment of the 2022 IPPS Proposed Rule summary next week. Until then, please remember that we at MiraMed Global Services are here to help you with your business needs. To view our array of services, please go to www.miramedgs.com or reach out to us at info@miramedgs.com.