eMeasures News You Can Use: Two pending rules, DSRIP, and more…

eMeasures News You Can Use:  Two pending rules, DSRIP, and more…

Introduction

Encore’s eMeasure Research and Review Board (eMRB) provides direction and common perspective on how eMeasures are applied in a value-based reimbursement environment.  To help keep others informed and share our knowledge, eMRB provides this high level monthly recap summarizing everything eMeasure-relevant that happened in March.

As you read through this March recap, you will notice it’s been a quiet month.  However, we anticipate things to pick up shortly with two important proposed rules related to eMeasures and new payment models expected out this week.  You’ll find those under the Watch List section.  Under Question of the Month, we cover a Medicaid performance-based incentive program and how it ties into quality measure reporting for the States.  We close with an announcement from our Encore Content & Requirements Team that the June 2015 Version of the eCQMs are now in CoreGPS.

Reading time:  11 minutes

Watch List 2016

March is looking like it may be “going out like a lion”

It’s been a fairly quiet month in the world of eMeasures.  Except for the HIMSS conference, not much has come out from CMS, but that’s about to change.  Therefore, we start with the most relevant news of the month, and that is the pending legislation we are watching for this week.

On the Watch List, we expect to see two proposed rules published by Friday, April 1, 2016.  They are:

Proposed Rules

1)      FY 2017 IPPS Proposed Rule

• The FY 2017 Hospital Inpatient Prospective Payment System (IPPS) Proposed Rule (NPRM) is pending review by the Office of Management and Budget (OMB); it was received on 3/21/2016.
• The annual proposed rule is due out on Friday, April 1, 2016; and the final rule is scheduled for August 1, 2016.

Why does it matter? 

• We are looking for the proposed 2017 requirements for the IQR program electronic clinical quality measures (eCQMs); and any new direction on the Meaningful Use Stage 3 requirements for hospitals.
• Most specifically, we are interested in how closely CMS will align hospital quality reporting requirements with the new physician quality reporting requirements being established under the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).

2)      MIPS and APMs in Medicare FFS Proposed Rule

• The Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) in Medicare Fee-for-Service (FFS) Proposed Rule is pending review by the OMB; it was received on 3/25/2016.
• The first annual proposed rule under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) legislation is due out in March (03/00/2016); and the final rule is scheduled for November 1, 2016.

Why does it matter?

• We are looking for the specifics on implementation of the MIPS and APMs and any alignment to the hospital based programs, especially for the EHR Incentive (Meaningful Use) Programs as well as clarification on what Accountable Care Organization risk-based tracks will count as an APM.

Other Relevant Legislative Activities

3)      Bill H.R.4848 – A Bill to delay and suspend implementation of a comprehensive care for joint replacement (CJR) payment model for episode-based payment for lower extremity joint replacement (LEJR) under the Medicare program in a budget neutral manner

• Short title is:  Healthy Inpatient Procedures Act of 2016” or the “HIP Act”.
• This bill was introduced to the House of Representatives on March 23, 2016 and referred to the Committee on Energy and Commerce, and to the Committee on Ways and Means.
• The Bill would delay and suspend implementation of the comprehensive care for joint replacement (CJR) payment model.
• Implementation of the CJR payment model begins on April 1, 2016; the Bill would change the implementation date to not begin before January 1, 2018.

Biggest impact of this bill will be to the approximately 800 hospitals required to participate in the model; it is an abrupt shift in payment for these high-volume procedures and the changes in care delivery they require.  The Bill would allow providers more adequate time to prepare for and implement the model resulting in less risk to patients, most especially patients with multiple chronic conditions.  (Reference:  CMS Innovation Center – Comprehensive Care for Joint Replacement)

4)      Other noteworthy industry comments:

• On 3/15/2016, the College of Healthcare Information Management Executives (CHIME) and other organizations sent a comment letter to CMS Acting Administrator Andy Slavitt asking for adoption of an any 90 day MU reporting period in 2016 as it was for 2015.
• On 3/17/2016, a hearing was held before the Committee on Energy and Commerce of the U.S. House of Representatives covering MACRA and payment reforms, which included statements made by American Hospital Association (AHA) and CHIME with regards to MACRA implementation of MIPS and APMs, and MU.  Both organizations stated the desire for CMS to streamline the MU program for hospitals and physicians and to remove the pass/fail “all-or-nothing” scoring construct of MU.
• On 3/3/2016, HHS announced they had reached the goal of tying 30 percent of Medicare payments to quality…ahead of schedule.  As of January 2016, CMS estimates that roughly $117 billion out of a projected $380 billion Medicare fee-for-service payments are tied to APMs, and ACOs represent about three quarters of progress toward the goal.

Why is this relevant?  If CMS is listening as they say they are, the industry comments will most likely have had an impact on the MIPS and APMs proposed rule expected out this week.  As well as, we expect the MIPS and APMs proposed rule will more clearly define the implementation path for tying Medicare payments to quality.

Question of the Month

eMeasure Research and Review Board’s Question of the month…

Question:  What is the Medicaid DSRIP program and how does it tie into the States quality measure reporting initiatives?

eMRB’s Answer:

DSRIP stands for Delivery System Reform Incentive Payment

• DSRIP programs are a component of Section 1115 of the Social Security Act, which allows the Secretary of Health and Human Services (HHS) to approve state Medicaid demonstration projects that waive statutory Medicaid requirements.
• DSRIPs are performance-based incentive programs.
• Providers must meet certain process or outcome measures to qualify for DSRIP funding; however, the methodology for allocating the funding across providers, demonstration years, and projects vary by state.

States Involved

As of March 2015, there were:

• Six states with DSRIP programs:  California, Kansas, Massachusetts, New Jersey, New York, and Texas.
• Two states with DSRIP-like programs:  New Mexico and Oregon; they resemble DSRIPs, but are less comprehensive and do not include funding for projects.
• Three states in process of developing DSRIP initiatives:  Alabama, New Hampshire, and Illinois.

DSRIP Quality Measures

• Each DSRIP program includes measurement of quality and performance improvement.  Similar measures include:
  • Implementation milestones and metrics measuring the DSRIP program.
  • Pay-For-Reporting metrics using standard national measures or adapted versions.
  • Pay-For-Performance metrics demonstrating improved care and outcomes.

• Most state DSRIP programs categorize metrics similarly, but there is limited overlap among states.

Source References:

Reference:  State Experiences Designing and Implementing Medicaid Delivery System Reform Incentive Payment (DSRIP) Pools

Reference:  June 2015 Report to Congress

Reference:  An Overview of Delivery System Reform Incentive Payment (DSRIP) Waivers

Reference:  Snapshot of Medicaid 1115 Waiver and Other State-Based Delivery System Transformations

Announcements

June 2015 Version of eCQMs now available in CoreGPS, Encore’s Measures Knowledgebase

The Encore Content & Requirements Team would like to announce the availability of the June 2015 Version of the eCQMs in CoreGPS.  For Eligible Hospitals (EH), all 29 measures are available.  Data guides are also available for all, with the exception of NQF 0716: Healthy Term Newborn (CMS has provided guidance to not report this measure electronically due to ongoing measure updates by the Steward).  For Eligible Professionals (EP), all 64 measures are available with data guides available for 18 of the measures.

Acronyms

Alternative Payment Model (APM); American Hospital Association (AHA); Calendar Year (CY);Centers for Medicare and Medicaid Services (CMS); College of Healthcare Information Management Executives (CHIME); Comprehensive Care for Joint Replacement (CJR); Delivery System Reform Incentive Payment (DSRIP); Electronic Clinical Quality Measures (eCQMs); Electronic Health Record(EHR); Eligible Hospital (EH); Eligible Professional (EP); eMeasure Research and Review Board(eMRB); Fiscal Year (FY); Health Information Management Systems Society (HIMSS); Healthy Inpatient Procedures Act of 2016 (HIP Act); Hospital Inpatient Quality Reporting Program (IQR);Medicare Access and CHIP (Children’s Health Insurance Program) Reauthorization Act of 2015(MACRA); Medicare Electronic Health Record (EHR) Incentive Program / Meaningful Use (MU); Medicare Shared Savings Program Accountable Care Organization (MSSP ACO); Merit-based Incentive Payment System (MIPS); National Quality Forum (NQF); Notice of Proposed Rule Making(NPRM); Office of the National Coordinator for Health Information Technology (ONC); U.S. Department of Health and Human Services (HHS).

To read previous versions of the eMeasures News You Can Use, you can locate them on Encore’s Website under the Press Room.

Points of view and interpretation were relevant at time of authorship; however, they are subject to change over time.

eMRB
Encore’s eMeasure Research and Review Board is made up of Encore’s industry thought leaders and eMeasure experts who are responsible for understanding the current state and future direction of quality and value-based programs for Encore’s business.

eMeasure Research and Review Board
Encore, A Quintiles Company
www.EncoreHealthResources.com