Inpatient Facility Coding & Compliance Alert

Cease submitting aspirin-on-delivery data — and other measures.

Sorting through the 2012 IPPS Final Rule is a daunting task, especially considering that changes affect areas ranging from Inpatient Prospective Payment System (IPPS) payments and the readmission reduction program to value-based purchasing, three-day payment window changes, and more. Your best tactic for success? Look at the big-picture changes, and tackle one at a time as they apply to your facility.

Operating rate change: Good news on the reimbursement front included the fact that the rule deferred part of the expected payment reductions until future years. Once several revisions are taken into consideration, the bottom line is that the FFY 2012 operating rate will increase by 0.9 percent when compared to FFY 2011. The federal inpatient operating rate will be $5,209.74 for FFY 2012, compared to $5,164.11 for FFY 2011. This was good news, considering CMS had originally proposed a 0.6 percent decrease.

More decreases will be coming, however. CMS intends to reduce the rate by 3.9 percent over a period of years to eliminate the effect of coding improvements and to implement certain statutory provisions contained in the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 (collectively known as the Affordable Care Act) and other legislation. The final rule has a 2.0 percent reduction and states that the remaining 1.9 percent reduction will be taken in the future. No proposed timeline for the adjustment has been published.

Quality reporting: The IPPS final rule showed CMS taking more steps toward aligning reporting requirements for the Value Based Purchasing program and the Hospital Inpatient Quality Reporting (HIQR) program. CMS adopted several new measures for FFY 2014 and FFY 2015 payment determinations, retired 4 measures, and suspended collection on 4 measures. The final rule does not add a healthcare-associated infection (HAI) measure, Central Line Insertion Practice Adherence Percentage (CLIP), to the HIQR Program as originally proposed.

CMS will retire the following measures from the HIQR Program beginning with FFY 2014 payment determinations:

• AMI-4: Adult smoking cessation advice/counseling
• HF-4: Adult smoking cessation advice/counseling
• PN-4: Adult smoking cessation advice/counseling
• PN-5c: Timing of receipt of initial antibiotic use

CMS is also suspending data collection for 4 measures beginning with Jan 1, 2012 discharges for the FFY 2014 payment determination (FR IPPS manual, page 153).

• AMI-1: Aspirin at arrival
• AMI-3: ACEI/ARB for left ventricular systolic dysfunction
• AMI-5: Beta-blocker prescribed at discharge
• SCIP INF-6 Appropriate Hair Removal

Hospitals will not be required to submit data on these measures beginning with Jan. 1, 2012 discharges. As proposed, CMS will add the following measures to the IQR Program beginning with FFY 2014 payment determinations:

• 1 Center for Disease Control and Prevention (CDC)/National Healthcare Safety Network (NHSN)-based HAI measure: Catheter Associated Urinary Tract Infection (CAUTI)
• 1 Claims-based measure: Medicare spending per beneficiary
• 1 structural measure: Participation in a Systematic Clinical Database Registry for General Surgery (FR IPPS manual, page 153).

A complete list of the 55 adopted HIQR Program measures for FFY 2014 payment determinations is available on Federal Register, see pages 51,628-51,629.