Inpatient Facility Coding & Compliance Alert

Heads up: Several new measures also apply to ASCs.

As part of its OPPS and ASC Final Rule for Calendar Year (CY) 2014, CMS announced numerous updates related to hospital quality. Most relate to the Hospital Outpatient Quality Reporting (OQR) Program, but don’t miss other tidbits about the Hospital Value-Based Purchasing (VBP) Program and conditions of coverage for Organ Procurement Organizations (OPO).

Add and Delete Quality Measures

The Final Rule finalized four new measures for the Hospital Outpatient Quality Reporting (OQR) Program. The changes will affect payment determinations for CY 2016 and beyond, with data collection beginning in CY 2014.

• Influenza Vaccination Coverage among Healthcare Personnel: CMS adopted this measure previously for the Hospital Inpatient Quality Reporting (IQR) Program for the FY 2015 payment determination and subsequent years.
• Endoscopy/Polyp Surveillance: Appropriate Follow-up Interval for Normal Colonoscopy in Average-Risk Patients: This measure was also adopted for the ASC Quality Reporting Program for the CY 2016 payment determination and subsequent years.
• Endoscopy/Polyp Surveillance: Colonoscopy Interval for Patients with a History of Adenomatous Polyps – Avoidance of Inappropriate Use: This measure was also adopted for the ASC Quality Reporting Program for the CY 2016 payment determination and subsequent years.
• Cataracts -- Improvement in Patient’s Visual Function Within 90 Days Following Cataract Surgery: This measure was also adopted for the ASC Quality Reporting Program for the CY 2016 payment determination and subsequent years.

ASC note: CMS now adopts the same cataract and colonoscopy measures for the ASC Quality Reporting (ASCQR) Program for the CY 2016 payment determination and subsequent years.

In addition, the Final Rule removes two measures for the CY 2015 payment determination and subsequent years:

• Transition Record with Specified Elements Received by Discharged ED Patients: CMS deleted this measure because it cannot be implemented with the degree of specificity needed to fully address stakeholders’ concerns without being overly burdensome to both hospitals and CMS.
• Cardiac Rehabilitation Measure: Patient Referral from an Outpatient Setting: This measure was eliminated due to continued difficulties accurately applying the measure to the hospital outpatient setting without creating undue burden on providers.

The Rule also codifies several administrative requirements and clarifies that the extraordinary circumstances waiver/extension includes certain systemic issues.

Review Value-Based Purchasing Time Frames

The rule establishes performance and baseline periods for three measures for the FY 2016 Hospital VBP Program:

• Catheter-associated urinary tract infection (CAUTI)
• Central line-associated bloodstream infection (CLABSI)
• Surgical site infection (SSI).

The final performance period is January 1, 2014 through December 31, 2014, and the final baseline period is January 1, 2012 through December 31, 2012.

Recourse: The rule also creates a second level independent CMS review process for hospitals that are dissatisfied with the result of their existing administrative appeal.

Many other details regarding quality reporting and other measures are in the Final Rule, scheduled for publication on December 10, 2013. Download a copy from the Federal Register at http://www.ofr.gov/inspection.aspx?AspxAutoDetectCookieSupport=1. On those issues to which comments can be made are due by January 27, 2014.