On April 10, 2024, the Centers for Medicare & Medicaid Services (CMS) issued the fiscal year (FY) 2025 Medicare hospital inpatient prospective payment system (IPPS) and long-term care hospital prospective payment system (LTCH PPS) proposed rule.
The proposed rule would update Medicare fee-for-service payment rates and policies for inpatient hospitals and LTCHs for FY 2025. CMS is publishing this proposed rule to meet the legal requirements to update Medicare payment policies for IPPS hospitals and LTCHs on an annual basis. This fact sheet discusses major provisions of the proposed rule, which can be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection/2024-07567/medicare-and-medicaid-programs-and-the-childrens-health-insurance-program-hospital-inpatient.
Background on the IPPS and LTCH PPS
CMS pays acute care hospitals (with a few exceptions specified in the law) for inpatient stays under the IPPS. LTCHs are paid under the LTCH PPS. Under these two payment systems, CMS sets base payment rates prospectively for inpatient stays, generally based on the patient’s diagnosis, the services or treatment provided, and severity of illness. Subject to certain adjustments, a hospital receives a single payment for each case depending on the payment classification assigned at discharge. The classification systems are for: IPPS, Medicare Severity Diagnosis-Related Groups (MS-DRGs) and for LTCH PPS, Medicare Severity Long-Term Care Diagnosis-Related Groups (MS-LTC-DRGs).
The law requires CMS to update payment rates for IPPS hospitals annually and to account for changes in the prices of goods and services used by these hospitals in treating Medicare patients, as well as for other factors. The index used to do this is known as the hospital “market basket.” The IPPS pays hospitals for services provided to Medicare beneficiaries using a national base payment rate, adjusted for a number of factors that affect hospitals’ costs, including the patient’s condition and the cost of hospital labor in the hospital’s geographic area. CMS updates LTCHs’ payment rates annually according to a separate market basket based on LTCH-specific goods and services.
Changes to Payment Rates under IPPS
The proposed increase in operating payment rates for general acute care hospitals paid under the IPPS that successfully participate in the Hospital Inpatient Quality Reporting (IQR) program and are meaningful electronic health record (EHR) users is projected to be 2.6%. This reflects a projected FY 2025 hospital market basket percentage increase of 3.0%, reduced by a 0.4 percentage point productivity adjustment.
Hospitals may be subject to other payment adjustments under the IPPS, including:
- Payment reductions for excess readmissions under the Hospital Readmissions Reduction Program (HRRP).
- Payment reduction (1%) for the worst-performing quartile of hospitals under the Hospital Acquired Condition (HAC) Reduction Program.
- Upward or downward adjustments under the Hospital Value-Based Purchasing (VBP) Program.
Overall, for FY 2025, CMS expects the proposed changes in operating and capital IPPS payment rates – in addition to other changes – will generally increase hospital payments by $3.2 billion. Specifically, the proposed increase in operating and capital IPPS payment rates will increase hospital payments in FY 2025 by approximately $2.9 billion. In addition, CMS projects Medicare uncompensated care payments to disproportionate share hospitals (DSH) will increase in FY 2025 by approximately $560 million. Subject to determinations on applications for additional payments for inpatient cases involving new medical technologies following a review of public comments on the proposed rule, CMS also estimates that additional payments for inpatient cases involving new medical technologies will increase by approximately $94 million in FY 2025, primarily driven by the continuation of new technology add-on payments for several technologies. Under current law, additional payments for Medicare-Dependent Hospitals (MDHs) and the temporary change in payments for low-volume hospitals are set to expire December 31, 2024. In the past, these payments have been extended by legislation, but if they were to expire, CMS estimates that payments to these hospitals would decrease by $0.4 billion in FY 2025.
Changes to Payment Rates under LTCH PPS
For FY 2025, CMS expects the LTCH standard payment rate to increase by 2.8% and LTCH PPS payments for discharges paid the LTCH standard payment rate to increase by approximately 1.2% or $26 million due primarily to a projected 1.3% decrease in high-cost outlier payments as a percentage of total LTCH PPS standard Federal payment rate payments. CMS is seeking comment on the proposed methodology used to determine the LTCH PPS outlier threshold for discharges paid the LTCH standard federal payment rate and an alternative methodology that would result in a lower outlier threshold.
Separate IPPS Payment for Establishing and Maintaining Access to Essential Medicines
Many hospitals have experienced drug shortages — from antibiotics used to treat severe bacterial infections to crash cart drugs necessary to stabilize and resuscitate critically ill adults. Shortages can have profound impacts on the care hospitals are able to provide to their patients, ranging from medication interactions to increased risk of hospital-acquired infections and in-hospital mortality. These impacts result in reduced quality of care and, in some instances, increased costs borne by the Medicare program to provide payment for avoidable services had a drug been readily available.
It is critical to develop policies that can help curtail shortages of essential medicines and associated impacts. As one part of this initiative, CMS is proposing a separate payment under the IPPS for small, independent hospitals to establish and maintain a buffer stock of essential medicines for use during future shortages. These hospitals are particularly vulnerable to supply disruptions during shortages because they lack the resources of hospitals that are larger and/or are part of a chain organization. This proposed policy would foster access to a more reliable, resilient supply of these medicines for patients of these hospitals.
Request for Information on the Use of the Medicare IPPS Payment Rates for Maternity Care by Other Payers
In alignment with the Biden-Harris Administration’s focus on maternal health, CMS is seeking information on differences between hospital resources required to provide inpatient pregnancy and childbirth services to Medicare patients as compared to non-Medicare patients. To the extent that the resources required differ between patient populations, we also wish to gather information on the extent to which non-Medicare payers or other commercial insurers may be using the IPPS as a basis for determining their payment rates for inpatient pregnancy and childbirth services as well as the effect, if any, that the use of the IPPS as a basis for determining payment by those payers may have on maternal health outcomes. Additionally, CMS is seeking public comment on potential solutions that can be implemented through the hospital CoPs to address well-documented concerns regarding maternal morbidity, mortality, disparities, and maternity care access in the United States without exacerbating access to care issues. Specifically, we solicit comment on what the overarching requirements and structure should be for a possible future obstetrical services CoP. We welcome data, alternatives, benefits, and discussion of possible unintended consequences.
Updated Labor Market Areas
The law requires that Medicare adjust its inpatient hospital payment for area differences in the cost of labor—an adjustment known as the wage index. CMS is proposing to revise the labor market areas used for the wage index based on the most recent core-based statistical area delineations issued by the Office of Management and Budget (OMB) based on 2020 Census data.
Continuation of the Low-Wage Hospital Policy
CMS proposes to extend a temporary policy finalized in the FY 2020 IPPS/LTCH PPS final rule that addresses wage index disparities affecting low-wage index hospitals, which includes many rural hospitals. Specifically, we are proposing that this policy would be effective for at least three more years, beginning in FY 2025. CMS believes it is necessary to wait until the low wage index hospital policy has been in place for a sufficient time period after the end of the COVID-19 public health emergency (PHE) to evaluate its effects before making any decision to modify or discontinue the policy. The first full fiscal year of wage data after the COVID-19 PHE is the FY 2024 wage data, which we anticipate will be available for FY 2028 rulemaking.
Distribution of GME residency slots under section 4122 of the Consolidated Appropriations Act (CAA), 2023
Section 4122 of the CAA, 2023, requires the distribution of an additional 200 Medicare-funded residency positions (or “slots”) to train physicians. Consistent with the Biden-Harris Administration’s Unity Agenda and focus on tackling the mental health crisis, this provision dedicates at least one-half of the total number of positions to psychiatry or psychiatry subspecialty residencies. The law requires CMS to notify hospitals receiving residency positions under section 4122 by January 31, 2026. In order to meet that deadline, CMS is proposing to implement policies that will govern the application and award process in a manner consistent with the statutory requirements. CMS is also proposing, to the extent slots are available, to focus on health professional shortage areas to help bolster the healthcare workforce in rural and underserved areas. CMS estimates that this additional funding will total approximately $74 million from FY 2026 through FY 2036.
Social Determinants of Health Diagnosis (SDOH) Codes
IPPS payment is made based on the use of hospital resources in the treatment of a patient’s severity of illness, complexity of service, and/or consumption of resources. Generally, a higher severity level designation of a diagnosis code results in a higher payment to reflect the increased hospital resource use. After review of our data analysis of the impact on resource use generated using claims data, CMS is proposing to change the severity designation of the seven ICD-10-CM diagnosis codes that describe inadequate housing and housing instability from non-complication or comorbidity (NonCC) to complication or comorbidity (CC), based on the higher average resource costs of cases with these diagnosis codes compared to similar cases without these codes. This builds on our policy from last year for diagnosis codes describing homelessness (e.g., unspecified, sheltered, and unsheltered). This proposal also aligns with the Biden-Harris Administration’s broader work to recognize the influence of social factors on health and resource use. The Administration’s broader work includes the efforts of the U.S. Interagency Council on Homelessness, which recognizes housing stability as essential to the health and well-being of individuals and families. The proposed policy, if finalized, would more accurately reflect each health care encounter for hospitals that take care of persons who have inadequate housing or have housing instability, and also improve the reliability and validity of the coded data including in support of efforts to advance health equity.
Changes to New Technology Add-on Payment (NTAP) for FY 2025
New gene therapies hold tremendous promise to cure previously incurable diseases, including sickle cell disease (SCD). To better promote access to these potentially lifesaving therapies, and consistent with CMS’ Sickle Cell Disease Action Plan, CMS is proposing to increase the NTAP percentage from 65% to 75% for a gene therapy that is indicated and used specifically for the treatment of SCD (subject to our determination in the FY 2025 IPPS/LTCH final rule that any applicable gene therapy(ies) indicated and used specifically for the treatment of SCD meets the criteria for approval for NTAP), beginning in FY 2025 and concluding at the end of the 2- to 3-year newness period of any such gene therapy.
To improve flexibility for applicants for NTAP, CMS is proposing to use the start of the fiscal year, October 1, instead of April 1, to determine whether a technology is within its 2- to 3-year newness period. This change would be effective starting in FY 2026 for new applicants for NTAP and when extending NTAP for an additional year for technologies initially approved for NTAP in FY 2025 or subsequent years.
Beginning with applications for NTAP for FY 2026, CMS is proposing to no longer consider an FDA marketing authorization hold status to be an inactive status for the purpose of the NTAP application eligibility.
Request for Information to Advance Patient Safety and Outcomes Across the Hospital Quality Programs
CMS is requesting feedback on ways to build on current measures in several quality reporting programs that account for unplanned patient hospital visits to encourage hospitals to improve discharge processes. While our hospital quality reporting and value-based purchasing programs currently encourage hospitals to address concerns about unplanned returns through several existing measures, we recognize that these measures, taken together, do not comprehensively capture unplanned patient returns to inpatient or outpatient care after discharge. We are specifically interested in input on adopting measures that better represent the range of outcomes of interest to patients, including unplanned returns to the emergency departments and receipt of observation services within 30 days of a patient’s discharge from an inpatient stay.
Hospital Inpatient Quality Reporting (IQR) Program
The Hospital IQR Program is a pay-for-reporting quality program that reduces payments to hospitals that do not meet program requirements. Hospitals that do not submit quality data or do not meet all Hospital IQR Program requirements are subject to a one-fourth reduction in their Annual Payment Update under the IPPS.
In the FY 2025 IPPS/LTCH PPS proposed rule, CMS is proposing to adopt seven new quality measures, remove five existing quality measures, and modify one current electronic clinical quality measures (eCQMs). CMS is also proposing two changes to current policies related to data validation: an increase over two years in the total number of mandatory eCQMs reported by hospitals and cross-program modifications to the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) Survey measure.
Specifically, CMS is proposing to adopt two new eCQMs, one claims-based measure, two structural measures, and two healthcare-associated infection (HAI) measures:
- Hospital Harm – Falls with Injury eCQM, with inclusion in the eCQM measure set beginning with the CY 2026 reporting period/FY 2028 payment determination.
- Hospital Harm – Post-operative Respiratory Failure eCQM, with inclusion in the eCQM measure set beginning with the CY 2026 reporting period/FY 2028 payment determination.
- Thirty-day Risk-Standardized Death Rate among Surgical Inpatients with Complications (Failure-to-Rescue) claims-based measure beginning with the July 1, 2023 – June 30, 2025 reporting period, which impacts the FY 2027 payment determination.
- Patient Safety Structural Measure beginning with the CY 2025 reporting period/FY 2027 payment determination.
- Age Friendly Hospital structural measure beginning with the CY 2025 reporting period/FY 2027 payment determination.
- Catheter-Associated Urinary Tract Infection Standardized Infection Ratio Stratified for Oncology Locations measure beginning with the CY 2026 reporting period/FY 2028 payment determination.
- Central Line-Associated Bloodstream Infection Standardized Infection Ratio Stratified for Oncology Locations measure beginning with the CY 2026 reporting period/FY 2028 payment determination.
CMS is proposing to modify the following measures:
- Global Malnutrition Composite Score eCQM beginning with the CY 2026 reporting period/FY 2028 payment determination. This modification adds patients ages 18 to 64 to the current cohort of patients 65 years or older.
- HCAHPS Survey in the Hospital IQR beginning with the CY 2025 reporting period/FY 2027 payment determination. The proposed updates would refine the current HCAHPS Survey measure by adding three new sub-measures, removing one existing sub-measure, and revising one existing sub-measure. The new survey sub-measures would include: “Care Coordination,” “Restfulness of Hospital Environment,” and “Information about Symptoms.” These three new sub-measures would be publicly reported beginning in October 2026. One current sub-sub-measure, “Care Transition,” would be removed from reporting on Hospital Compare in January 2026. Additionally, the current “Responsiveness of Hospital Staff” sub-measure would be altered starting in January 2025, with the “Call Button” questions being removed from the survey and a new “Get Help” question being added.
CMS is proposing to remove five measures:
- Four payment measures:
- Hospital-level, Risk-Standardized Payment Associated with a 30-Day Episode of Care for Acute Myocardial Infarction (AMI Payment).
- Hospital-level, Risk-Standardized Payment Associated with a 30-Day Episode of Care for Heart Failure (HF Payment).
- Hospital-level, Risk-Standardized Payment Associated with a 30-Day Episode of Care for Pneumonia (PN Payment).
- Hospital-level, Risk-Standardized Payment Associated with a 30-day Episode of Care for Elective Primary Total Hip Arthroplasty and/or Total Knee Arthroplasty (THA/TKA Payment).
- We are proposing these removals beginning with the FY 2026 payment determination, which is associated with a performance period of: July 1, 2021 – June 30, 2024, for the AMI Payment, HF Payment, and PN Payment measures and April 1, 2021 – March 31, 2024 for the THA/TKA Payment measure. These four measures are condition-specific assessments of hospital risk-standardized payment associated with a 30-day episode of care for AMI, HF, PN, and THA/TKA. We are proposing to remove these measures due to the availability of a more broadly applicable measure, specifically the Medicare Spending Per Beneficiary-Hospital measure (MSPB Hospital) in the Hospital VBP Program. The MSPB Hospital measure evaluates hospitals’ efficiency and resource use relative to the efficiency of the national median hospital. We also note that performance on these measures has either stayed stable (THA/TKA Payment) or decreased (PN Payment, HF Payment, AMI Payment) since FY 2019. By removing these measures, we create more room in the program’s measure set for new clinical topics.
- CMS PSI-04 Death Among Surgical Inpatients with Serious Treatable Complications measure beginning with the FY 2027 payment determination, associated with a July 1, 2023 – June 30, 2025 reporting period. This claims-based measure records in-hospital deaths per 1,000 elective surgical discharges among patients ages 18 through 89 years old or obstetric patients with serious treatable complications. We are proposing to remove this measure due to the availability of a more broadly applicable measure, namely the Failure-to-Rescue measure proposed for adoption above.
- CMS is proposing to increase the total number of eCQMs reported from six to eleven over two years. Currently, the Hospital IQR Program requires reporting of six total eCQMs, three selected by CMS and three self-selected by hospitals. For the CY 2026 reporting period/FY 2028 payment determination, we are proposing that hospitals report on nine total eCQMs, with six selected by CMS and three self-selected by hospitals. For the CY 2027 reporting period/FY 2029 payment determination, we are proposing that hospitals report on 11 total eCQMs, with eight selected by CMS and three self-selected by hospitals.
- CMS is proposing two modifications to data validation requirements. First, CMS is proposing to modify the current data validation scoring to implement two separate validation scores, one for clinical processes of care (CPOC) measures and one for eCQMs, and equally weighting them at 50% each. Previously, eCQM validation was weighted at zero to give hospitals time to gain experience with eCQM reporting and validation. Based on recent validation periods, CMS believes that hospitals are ready to be assessed using an eCQM validation score that is distinct from the current CPOC validation score. Second, we are proposing to modify the data validation reconsideration request requirements to make medical records submission optional for reconsideration requests beginning with FY 2026 data validation/CY 2023 discharges. This modification will remove a redundant and inefficient step in the current process, as hospitals usually submit the same records that they used for quality reporting. However, this change will still allow hospitals to submit additional records as part of their reconsideration request if appropriate.
Medicare Promoting Interoperability Program
In 2011, CMS established the Medicare and Medicaid EHR Incentive Programs to encourage eligible professionals, eligible hospitals, and critical access hospitals (CAHs) to adopt, implement, upgrade, and demonstrate meaningful use of certified electronic health record (EHR) technology (CEHRT). For eligible hospitals and CAHs, that program is now known as the Medicare Promoting Interoperability Program.
In the FY 2025 IPPS/LTCH PPS proposed rule, CMS is proposing to separate one existing measure into two distinct measures, proposing to adopt two new eCQMs, proposing to modify one current eCQM, proposing to increase the performance-based scoring threshold, notifying eligible hospitals and CAHs of one Request for Information. CMS is also proposing to increase the total number of mandatory eCQMs reported by hospitals over two years.
CMS is proposing the following measure-related proposals in the Medicare Promoting Interoperability Program for eligible hospitals and CAHs:
- Separate the Antimicrobial Use and Resistance (AUR) Surveillance measure into two measures, Antimicrobial Use (AU) Surveillance and Antimicrobial Resistance (AR) Surveillance, beginning with the EHR reporting period in CY 2025; add a new exclusion for eligible hospitals or CAHs that lack discrete electronic access to data elements that are required for AU or AR Surveillance reporting; modify the applicability of the existing exclusions for the AUR Surveillance measure to apply to the proposed AU Surveillance and AR Surveillance measures, respectively; and treat the AU Surveillance and AR Surveillance measures as two new measures with respect to active engagement beginning with the EHR reporting period in CY 2025.
- Adopt two new eCQMs for eligible hospitals and CAHs to select as one of their three self-selected eCQMs, in alignment with the Hospital IQR Program, beginning with the CY 2026 reporting period:
- Hospital Harm – Falls with Injury eCQM.
- Hospital Harm – Postoperative Respiratory Failure eCQM.
- Modify the Global Malnutrition Composite Score eCQM by adding patients ages 18 to 64 to the current cohort of patients 65 years or older.
- Modify eCQM data reporting and submission requirements in alignment with the Hospital IQR Program by proposing a progressive increase in the number of mandatory eCQMs eligible hospitals and CAHs would be required to report on beginning with the EHR reporting period in CY 2026.
CMS is notifying eligible hospitals and CAHs of the following:
- Notifying eligible hospitals and CAHs of the changes to the definition of CEHRT in the Medicare Promoting Interoperability Program at 42 CFR 495.4 beginning with the CY 2024 EHR reporting period based on revisions made in the CY 2024 Medicare Physician Fee Schedule final rule.
- Notifying eligible hospitals and CAHs of the proposed changes to the definition of Meaningful EHR User at 42 CFR 495.4 in the Department of Health and Human Services (HHS) proposed rule, 21st Century Cures Act: Establishment of Disincentives for Health Care Providers That Have Committed Information Blocking (hereafter referred to as the HHS proposed rule).
CMS is also issuing an RFI describing goals and principles for the Medicare Promoting Interoperability Program’s Public Health and Clinical Data Reporting objective and soliciting feedback in response to a series of questions related to that objective and related topic.
CMS is also proposing to increase the performance-based scoring threshold for eligible hospitals and CAHs reporting to the Medicare Promoting Interoperability Program from 60 points to 80 points beginning with the EHR reporting period in CY 2025.
PPS-Exempt Cancer Hospital Quality Reporting (PCHQR) Program
The PCHQR Program is a quality reporting program for the eleven cancer hospitals that are statutorily exempt from the IPPS. CMS collects and publishes data from PCHs on applicable quality measures. In the FY 2025 IPPS/LTCH PPS proposed rule, CMS is proposing the following:
- Adopt the Patient Safety Structural measure beginning with the CY 2025 reporting period/FY 2027 program year.
- Modify the HCAHPS Survey measure beginning with the CY 2025 reporting period/FY 2027 program year. These changes are the same as mentioned above in the Hospital IQR Program,
- Move up the start date for publicly displaying hospital performance on the Hospital Commitment to Health Equity measure to January 2026 or as soon as feasible thereafter.
Hospital Readmissions Reduction Program
The Hospital Readmissions Reduction Program is a value-based purchasing program that reduces payments to hospitals with excess readmissions. It also supports CMS’ goal of improving health care for patients by linking payment to the quality of hospital care. CMS is not proposing any changes to the Hospital Readmissions Reduction Program in the FY 2025 IPPS/LTCH PPS proposed rule. We note that all previously finalized policies under this program will continue to apply and refer readers to the FY 2023 IPPS/LTCH PPS final rule (87 FR 49081 through 49094) for information on these policies.
Hospital-Acquired Condition (HAC) Reduction Program
The HAC Reduction Program creates an incentive for hospitals to reduce the incidence of hospital-acquired conditions by reducing payment by 1% for applicable hospitals that rank in the worst-performing quartile on select measures of hospital-acquired conditions. CMS is not proposing any changes to the HAC Reduction Program in the FY 2025 IPPS/LTCH PPS proposed rule. We note that all previously finalized policies under this program will continue to apply and refer readers to the FY 2024 IPPS/LTCH PPS final rule (88 FR 59108 through 59114) for information on these policies.
Hospital Value-Based Purchasing (VBP) Program
The Hospital VBP Program is a budget-neutral program funded by reducing participating hospitals’ base operating DRG payments each fiscal year by 2% and redistributing the entire amount back to the hospitals as value-based incentive payments. In the FY 2025 IPPS/LTCH PPS proposed rule, CMS is proposing to:
- Modify scoring on the HCAHPS Survey measure in the Person and Community Engagement Domain for the FY 2027 through FY 2029 program years to only score on the six unchanged dimensions of the survey while updates to the survey are adopted and publicly reported on in the Hospital IQR Program.
- Adopt measure updates to the HCAHPS Survey measure in the Person and Community Engagement Domain beginning with the FY 2030 program year after the updates have been publicly reported for one year in the Hospital IQR Program.
- Modify scoring on the HCAHPS Survey measure in the Person and Community Engagement Domain beginning with the FY 2030 program year to account for the updates to the survey.
Long-Term Care Hospital Quality Reporting Program (LTCH QRP)
The LTCH QRP is a pay-for-reporting program. LTCHs that do not meet reporting requirements are subject to a two-percentage-point reduction in their Annual Payment Update. In the FY 2025 IPPS/LTCH PPS proposed rule, CMS is proposing to add four items, modify one item, and modify one administrative requirement for the LTCH Continuity Assessment Record and Evaluation (CARE) Data Set (LCDS), as well as two RFIs), for the LTCH QRP.
- Beginning with the FY 2028 LTCH QRP (beginning with patients admitted on October 1, 2026), CMS is proposing to adopt four new Social Determinants of Health (SDOH) items and modify one SDOH item for the LTCH QRP.in the LCDS under the following categories: (1) one item for Living Situation; (2) two items for Food; and (3) one item for Utility. Among other reasons, screening for SDOH via collecting these items, may assist LTCHs better address those identified needs with the patient, their caregivers, and community partners during the discharge planning process, if indicated.
Beginning with the FY 2028 LTCH QRP (beginning with patients admitted on October 1, 2026), CMS is proposing to modify the Transportation assessment item under the SDOH Category. As part of our routine item and measure monitoring work, we have identified an opportunity to improve the data collection for this item. Specifically, the proposed Transportation item modification will improve and align data collection in three ways: (1) the guidance will clarify the look-back period for when a patient experienced a lack of reliable transportation, (2) the response options will be simplified for the patient, and (3) the revised assessment item will be collected at admission only, which will decrease provider burden since the current assessment item is collected at both admission and discharge.
- Beginning with the FY 2028 LTCH QRP (beginning with patients admitted on October 1, 2026), CMS is proposing to modify the required assessment window for LTCHs to administer the LCDS and collect information on the LCDS Admission assessment period from three days to extend it to four days in response to feedback regarding the difficulty of collecting the required LCDS data elements within the three-day assessment window when medically complex patients are admitted prior to and on weekends.
In addition, CMS is seeking feedback on two RFIs:
- Future Measure Concepts for the LTCH QRP: The purpose of this RFI is to receive feedback on potential measurement concepts that could be developed into LTCH QRP measures. CMS continues to evaluate, refine, and develop new QRP measures to ensure that Medicare beneficiaries and their caregivers have meaningful information for making informed healthcare decisions. Specifically, CMS is seeking input on the measure concepts of pain management, depression, and a composite measure of vaccinations.
- LTCH QRP Star Rating System: Currently, the LTCH QRP does not have a star rating system to supplement existing publicly reported quality information for individuals to use when comparing LTCH quality of care. CMS intends to develop a five-star methodology for LTCHs that can meaningfully distinguish quality of care offered by providers and would also be reported on both Care Compare and the Provider Data Catalog. Star ratings for LTCHs will be designed to help consumers quickly identify differences in quality when selecting a provider while also helping to promote competition in health care markets. We invite public comment on the following questions: (1) Are there specific criteria CMS should use to select measures for a star rating system? (2) How should CMS present star rating information in a way that is most useful to consumers?
Hospital and CAH Data Reporting
CMS is proposing to update the hospital and CAH infection prevention and control and antibiotic stewardship programs' Conditions of Participation (CoPs) to extend a subset of the current COVID-19 and influenza data reporting requirements. This approach will balance the need for robust and accurate data for virus surveillance with the burden that this can place on facilities and their staff. CMS continues to believe that sustained data collection and reporting of respiratory illnesses outside of emergencies will help hospitals and CAHs gain important insights related to their evolving infection control needs. Specifically, CMS is proposing to replace the COVID-19 and Seasonal Influenza reporting standards for hospitals and CAHs with a new standard that will address acute respiratory illnesses. This new standard would require that beginning on October 1, 2024, hospitals and CAHs would have to electronically report certain data elements about COVID-19, influenza, and respiratory syncytial virus (RSV). The proposed information for which reporting would be required includes confirmed infections of respiratory illnesses, including COVID-19, influenza, and RSV, among hospitalized patients; hospital bed census and capacity; and limited patient demographic information, including age. CMS is proposing that, outside of a public health emergency (PHE), hospitals and CAHs would have to report these data on a weekly basis.
CMS also recognizes that, while necessary, these data may not be sufficient during an actual emergency scenario. Accordingly, we are also proposing that in the event of a declared national PHE for an acute respiratory illness, there may be additional categories of reporting required, such as: facility structure and infrastructure operational status; hospital/ED diversion status; staffing and staffing shortages; supply inventory shortages; and relevant medical countermeasures and therapeutics.
CMS is seeking comment on ways the reporting burden can be minimized while still providing adequate data; whether we should expand the proposed requirements for what is collected and how often, both outside a declared PHE; the value of these data in protecting the health and safety of individuals receiving treatment and working in hospitals and CAHs both during and outside of a PHE; system readiness and capacity to collect and report these data, and whether race/ethnicity or other demographic information, such as socioeconomic factors or disability status, should be included in the requirements for ongoing reporting beginning on October 1, 2024.
Lastly, CMS is issuing an RFI to better understand actions the agency can take to strengthen hospital and CAH participation in and timely, complete data reporting through CDC’s National Syndromic Surveillance Program (NSSP). CMS is seeking input on potential additional actions it could take, including:
- Requiring hospitals and CAHs to report data to CDC’s NSSP (in addition to state/local syndromic surveillance systems).
- Requiring or otherwise incentivizing hospitals and CAHs to expand admission, discharge, and transfer-based syndromic surveillance reporting to inpatient settings.
For more information, please visit: https://www.cms.gov/priorities/innovation/innovation-models/transforming-clinical-practices.
For the Transforming Episode Accountability Model (TEAM) fact sheet, visit: https://www.cms.gov/files/document/team-model-fs.pdf.
###