HIMSS Submits Comments in Response to the Proposed Inpatient Prospective Payment Systems Annual Update

On Friday, July 10, HIMSS provided written comments in response to a Notice of Proposed Rulemaking (NPRM) for the Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2021 Rates; Quality Reporting and Medicare and Medicaid Promoting Interoperability Programs Requirements for Eligible Hospitals and Critical Access Hospitals.

Recommendations to the Centers for Medicare and Medicaid Services (CMS) specifically touched upon areas that addressed Electronic Clinical Quality Measure reporting for the Inpatient Quality Reporting Program, increasing the quarterly reporting of quality data, mandatory reporting of the Hybrid Hospital-Wide Mortality measure and mandatory reporting of the Safe Use of Opioid measure.

Electronic Clinical Quality Measure (eCQM) Reporting for the Inpatient Quality Reporting (IQR) Program

In regard to overarching recommendations for the development of quality reporting policies for the IQR program, HIMSS has historically addressed, and continues to lean on the following recommendations:

• Any new eCQMs that CMS considers adding to the current eligible hospital (EH) eCQM measure set should be feasible, actionable in as close to real-time as possible, accurately reflect the quality of care delivered and be designed to capture data as part of a normal care delivery workflow.
• CMS quality reporting policies should strive to enhance the value proposition of participating in quality reporting programs and ensure that eCQMs are actionable and meaningful for EHs as well as patients to drive improvement in care outcomes.
• The removal of a measure from the CMS measure set should not only characterize where a gap in care can be prevented, but the remaining measures should continue to fully represent the high impact areas of the care domain. In doing so, CMS policies should balance reducing burden on providers and developers by using data already collected for care and without introduction of new inefficient workflows.
• CMS should incentivize EH participation in the development and testing of new eCQMs, and furthermore, the utilization of technology that visualizes real-time performance on eCQMs.

Increasing the Quarterly Reporting of Quality Data

HIMSS is supportive of the proposal to progressively increase the number of quarters of eCQM data reported, from one self-selected quarter of data to four quarters of data over a 3-year period.

In this letter, HIMSS requested that CMS clarify the timeline for the transition to QI Core FHIR CQL in the final rulemaking, stressing if underlying standards change for certified EHR technology, the potential impact on workflows would require a slower transition.

Mandatory Reporting of the Hybrid Hospital-Wide Mortality (HWR) Measure Starting in 2024

HIMSS offered support for the proposed adoption of the Reporting Hybrid Hospital-Wide Readmission (HWR) with EHR Data quality measure as part of the IQR Program. The Hybrid HWR uses clinical data elements, making the measure more conducive to quick and detailed root-cause analysis than claims-based outcomes measures.

HIMSS also noted that reporting data through Quality Reporting Document Architecture (QRDA) I for hybrid measures continues to be burdensome for EHs, and CMS should use mandatory reporting to identify potential barriers with data capture and reporting and correct those barriers before weighing performance on the HWR measure in reimbursement determinations.

Mandatory Reporting of the Safe Use of Opioid Measure

HIMSS expressed support for the inclusion and mandatory reporting of the Safe Use of Opioids—Concurrent Prescribing eCQM in the IQR eCQM measure set. Like the Hybrid HWR measure, HIMSS recommends that CMS require the mandatory reporting of the Safe Use of Opioids measure in CY2021. HIMSS noted that voluntary reporting for CMS measures does not historically generate the capture and reporting of the measure in enough volume to identify solutions to challenges with data mapping and capture. Mandating the reporting of the Safe Use of Opioids measure will allow CMS to capture the volume of data required to identify challenges with mapping and reporting.

Read the entire comment letter and direct and questions to policy@himss.org.