Regulatory Update - Hospital Inpatient Prospective Payment System (IPPS) proposed rules for FY 2015

The IPPS program includes infection related measures in several parts of the program:

• Hospital Acquired Conditions – Non-payment for certain secondary conditions when condition is acquired during hospitalization (includes several HAIs).

• Hospital Inpatient Quality Reporting Program (IQR) – Incentivized payment for reporting certain quality measures (including required NHSN reporting) to CMS so consumers make more informed decisions about their care.  Hospitals that do not participate in the IQR program receive a 2% reduction in payment.

• Hospital Value-based Purchasing (VBP) – Incentivized payment systems that rewards hospitals for the quality of care they provide based on a Total Performance Score in a performance period.   A hospital’s adjustment factor may be positive, negative or result in no change in the payment rate that would apply absent the VBP program.

• Hospital-Acquired Conditions (HAC) Reduction Program – Payment penalty program that requires CMS to reduce hospital payments by 1% for hospitals that rank among the lowest performing 25% with regard to HACs.

• Long-Term [Acute] Care Quality Reporting Program (LTCHQRP)

• PPS-exempt Cancer Hospital Quality Reporting Program (PCHQRP)

Hospital VBP measures proposed for FY 2017 paymentsMeasures proposed for removalFor FY 2017, CMS proposes to remove three “topped-out” infection-related measures, meaning that all hospital scores are uniformly high and the measure is no longer able to make meaningful distinctions.

• SCIP-Inf-2 – Prophylactic antibiotic selection for surgical patients
• SCIP-Inf-3 – Prophylactic antibiotics discontinued within 24 hrs after surgery end time
• SCIP-Inf-9 – Postoperative urinary catheter removal on postoperative day 1 or 2

Measures proposed for addition
Two infection-related measures are proposed for addition to the VBP measure set beginning with FY 2017 payment.  The baseline period for this data was Jan. 1, 2013 – Dec. 31, 2013 and the performance period will begin Jan. 1, 2015 – Dec. 31, 2015.

• MRSA bacteremia LabID event
• C. difficile LabID event

Hospital IQR Program measures proposed for FY 2017 payment
Measures proposed for removal
CMS proposes to remove 6 “topped-out” infection-related measures:

• SCIP-Inf-1 – Prophylactic antibiotics received within one hour prior to surgical incision
• SCIP-Inf-2 – Prophylactic antibiotic selection for surgical patients
• SCIP-Inf-3 – Prophylactic antibiotics discontinued within 24 hrs. after surgery end time
• SCIP-Inf-4 – Cardiac surgery patients with controlled postoperative blood glucose
• SCIP-Inf-6 – Surgery patients with appropriate hair removal
• SCIP-Inf-9 – Postoperative urinary catheter removal on postoperative day 1 or 2

Measures proposed for addition
CMS has no new proposed measures in this year’s rule.  Measures already being reported:  CLABSI, CAUTI, SSI COLO and HYST, MRSA bacteremia LabID events, C. difficile LabID events.

Hospital-Acquired Conditions (HAC) Reduction ProgramCMS does not propose any changes to the measures previously adopted for the HAC Reduction Program.  Already approved measures are:
       Domain 1:

• AHRQ PSI-90 composite measure

Domain 2 (CDC HAI measures):

• CLABSI
• CAUTI
• SSI COLO and HYST
• MRSA Bacteremia LabID Events
• C. difficile LabID Events

Long-Term [Acute] Care Quality Reporting Program measures proposed for FY 2018 payments
CMS has proposed the addition of the NHSN Ventilator-Associated Events (VAE) measure for inclusion in the LTCQRP.  Measures already included in the LTCHQRP are:

• CAUTI
• CLABSI
• HCP Influenza Vaccination
• MRSA Bacteremia LabID Events
• C. difficile LabID Events

PPS-exempt Cancer Hospital Quality Reporting Program measures proposed
CMS has no new proposed HAI measures in this year’s rule.  They have proposed delaying making CLABSI and CAUTI data public until 2017.