Certified EHRs Expected to Transmit Data for Medicare’s New Hospital Inpatient Value-Based Purchasing Program

On January 13, 2011, the Centers for Medicare and Medicaid Services (CMS) released its Proposed Rule on the Medicare Hospital Inpatient Value-Based Purchasing (VBP) Program. The VPB Program is being established per the directive of the Patient Protection and Affordable Access to Care Act of 2010 (PPACA). CMS is to begin making incentive payments under the VBP Program for discharges on or after October 1, 2012.

Seven years before PPACA required CMS to establish the VBP Incentive Program, the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) gave CMS authority to establish the Hospital Inpatient Quality Reporting (IQR) Program. The clinical quality measures that CMS has adopted for the IQR Program will feed into the measures for the VBP Program.

The IQR Program measures were generally based on recommendations from the National Quality Forum (NQF), a voluntary consensus standard-setting organization with a diverse representation of consumer, purchaser, provider, academic, clinical, and other health care stakeholder organizations. The IQR measures began as a set of 10 quality indicators that have since expanded to 45 clinical quality measures for the FY 2011 IQR program payment determination. The FY 2011 IQR hospital measures focus on four topics: 1) Acute Myocardial Infarction (AMI); 2) Heart Failure (HF); 3) Pneumonia (PN); and 4) Surgical Care Improvement Project (SCIP).

So how does this relate to the Health Information Technology for Economic and Clinical Health Act (HITECH Act) and a hospital’s “meaningful use” of a “certified EHR“? Ahhh, there is a method to the madness. As the CMS VBP Proposed Rule points out, the Hospital IQR program and the Hospital VBP Program have “important areas of overlap and synergy with regard to the reporting of quality measures under the HITECH Act.”

CMS notes in the Proposed Rule that the certification standards for EHRs under the HITECH Act are directed at enabling EHR submission of quality measures. CMS is striving “to align the [VPB] measures with the adoption of meaningful use standards for health information technology (HIT), so the collection of performance information is part of care delivery.” As a result, CMS anticipates that hospitals will use their certified EHRs for the reporting of clinical quality measures under both the Hospital IQR program and the subsequent Hospital VBP Program.

The proposed initial measures for the FY 2013 Hospital VBP Program include 18 measures. Of these 18 measures, 17 measures will focus on the four clinical process of care topics set forth for the 2011 IQR Program (AMI, HF, PN, and SCIP), and will add Healthcare-Associated Infections (HAI). The 18th measure will include a measure from the Hospital Consumer Assessment of Healthcare Providers and Systems Survey (HCAHPS) that will fall under a patient experience of care domain.

The proposed performance period is to begin July 1, 2011 and will continue through March 31, 2012 for the FY 2013 payment determination. This is already less than five months away! Another reason for Eligible Hospitals under the HITECH Act to focus on implementation of a certified EHR. Did I hear someone ask how the VBP incentive payments will be funded? Answer: By a reduction of the Fiscal Year 2013 base operating DRG payments for each discharge of 1%. “What one hand giveth, the other hand taketh away.” (Unknown)

For more information about the IQR Program, visit QualityNet.  For additional details about the VBP Program, see the Proposed Rule.  CMS will accept comments on the VBP Proposed Rule until March 8, 2011.  CMS expects to issue a final rule in 2012.

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