Monday, August 12, 2013

2014 Proposed HAI Reporting Requirements



Per North Carolina Administrative Code (10A NCAC 41A .0106, 10A NCAC 41), Reporting of Healthcare-Associated Infections (HAIs) in North Carolina is based on the Centers for Medicare and Medicaid Services (CMS) Inpatient Prospective Payment System (IPPS) rules (Rules on Inpatient Prospective Payment Services). Because of this, when CMS adds HAI reporting rules, North Carolina requires those same HAIs be reported to the Division of Public Health (DPH) through the National Healthcare Safety Network (NHSN).

Recently, CMS published proposed rules for 2014 for public comment (http://www.gpo.gov/fdsys/pkg/FR-2013-05-10/pdf/2013-10234.pdf). If these rules are adopted they will affect you and your reporting of HAIs to CMS and to North Carolina. Two proposed rules in particular will impact data entry, beginning on or after January 1, 2014. These include:

1. Acute Care Hospitals will be required to report Central Line Associated Blood Stream Infections (CLABSIs) and Catheter Associated Urinary Tract Infections (CAUTIs) from not only all ICUS, but all medical, surgical, and medical/surgical wards.

2. The Medicare Beneficiary Number is to be reported (when applicable) for patients for all NHSN reported events.

It is currently unknown when CMS will publish the final rules so watch for information from the DPH HAI Infection Prevention Program, APIC NC and SPICE concerning the final rules.

Of additional interest regarding CMS’ validation process for 2013 data, CMS proposes to include CLABSI, CAUTI, SSI (Colon and Hysterectomy), LabID MRSA bacteremia and CDI.

For further information, you can read comments made on the proposed rules by national APIC at: http://www.apic.org/Resource_/TinyMceFileManager/Advocacy-PDFs/Comments_on_IPPS_FY_2014_FINAL_6-24-13.pdf

Special Note: In the FY 2014 IPPS proposed rule, CMS inadvertently omitted the baseline period for the CAUTI, CLABSI, and SSI measures that were proposed to be added to the Value Based Program (VBP) for FY 2016 payment. In in their comments (see website above), APIC asked for clarification on this point, and CMS added it to the OPPS/ASC proposed rule in order to get public comments in time to finalize the measures before the start of FY 2014 (October 1, 2013).
  • The performance period for these measures is January 1, 2014 – December 31, 2014. The proposed baseline period is January 1 – December 31, 2012.