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IPFQR Program: FY 2018 IPPS Proposed Rule Jeffrey A. Buck, Ph.D. Senior Advisor for Behavioral Health Program Lead, IPFQR Program CMS Evette Robinson, MPH Project Lead, IPFQR Program VIQR Outreach and Education Support Contractor May 3, 2017
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Acronyms APA CEO CMS CY DOD ECE FFS FR FY IPF IPFQR IPPS IQR MDD NOP PPS VA VIQR American Psychiatric Association Chief Executive Officer Centers for Medicare & Medicaid Services Calendar Year Department of Defense Extraordinary Circumstances Exception Fee-For-Service Federal Register Fiscal Year Inpatient Psychiatric Facility Inpatient Psychiatric Facility Quality Reporting Inpatient Prospective Payment System Inpatient Quality Reporting Major Depressive Disorder Notice of Participation Prospective Payment System Department of Veterans Affairs Value, Incentives, and Quality Reporting 7
Purpose This presentation will summarize the proposed updates to the IPFQR Program quality measure requirements and the proposed administrative changes, as outlined in the FY 2018 IPPS Proposed Rule. 8
Learning Objectives At the conclusion of this presentation, attendees will be able to: Interpret the FY 2018 IPPS Proposed Rule, as it pertains to the IPFQR Program Describe the proposed measure and the proposed administrative changes to the IPFQR Program. 9
IPFQR Program: FY 2018 IPPS Proposed Rule Overview of the Proposed Rule 10
Functions of the Proposed Rule Publication of the Proposed Rule enables CMS to achieve the following: Inform IPFQR Program participants about intended modifications to the program Solicit public comment on proposed changes Provide ample time for IPFs to prepare for changes that are likely to be confirmed in the Final Rule 11
Summary of Proposed Changes: New Measure CMS proposes one new claims-based measure for the FY 2020 payment determination and subsequent years: Medication Continuation Following Inpatient Psychiatric Discharge 12
Summary of Proposed Changes: Administrative Changes CMS proposed administrative changes: Establish criteria to evaluate measures for retention or removal Change timeframe specifications for the following: data submission period NOP or program withdrawal submissions Modify the IPFQR Program s ECE policy Solicit input in a Request for Information from stakeholders concerning ideas for regulatory, policy, practice, and procedural changes to better achieve transparency, flexibility, program simplification and innovation NOTE: We do not believe that these changes will have an impact on burden for stakeholders of the IPFQR Program. 13
IPFQR Program: FY 2018 IPPS Proposed Rule Medication Continuation Following Inpatient Psychiatric Discharge Measure 14
Proposed Medication Continuation Measure: Background CMS believes that medication continuation is important for patients discharged from the inpatient psychiatric setting with MDD, schizophrenia, or bipolar disorder because of significant negative outcomes associated with non-adherence to medication regimens. Patients with MDD who do not remain on prescribed medications are more likely to have negative health outcomes, such as relapse and readmission, decreased quality of life, and increased healthcare costs. Patients with schizophrenia who do not adhere to their medication regimen are more likely to be hospitalized, use emergency psychiatric services, be arrested, be victims of crimes, and consume alcohol or drugs compared to those who adhere to their medication regimen. Patients with bipolar disorder who do not adhere to their medications have increased suicide risk. 15
Proposed Medication Continuation Measure: Measure Description The measure addresses the percentage of Medicare FFS beneficiaries aged 18 years and older who were discharged from an IPF to home or health care with a principal diagnosis of MDD, Schizophrenia, or Bipolar Disorder who had filled at least one evidence-based medication within two days prior to discharge through 30 days post-discharge. 16
Proposed Medication Continuation Measure: Denominator Statement The number of patients aged 18 years and older who were discharged from an IPF to home or home health care with a principal diagnosis of MDD, schizophrenia, or bipolar disorder. 17
Proposed Medication Continuation Measure: Numerator Statement The number of patients with a principal diagnosis of MDD, schizophrenia, or bipolar disorder who were dispensed at least one evidence-based outpatient medication within two days prior to discharge through 30 days post-discharge. 18
Proposed Medication Continuation Measure: Reporting Requirements The Medication Continuation Following Inpatient Psychiatric Discharge measure is claims-based. CMS will calculate and report the measure rates based on Medicare FFS Parts A, B, and D claims; therefore, IPFs are not required to collect or report data for this measure. The measure will be reported as a combined facility level rate across all three conditions. The measurement period is two years, in order to maximize the number of facilities with the minimum of 75 discharges necessary for reliable facility-level scores. 19
Proposed Medication Continuation Measure: Resources Reference materials that describe additional details about the Medication Continuation Following Inpatient Psychiatric Discharge measure are available at https://www.cms.gov/medicare/quality-initiatives-patient- Assessment-Instruments/HospitalQualityInits/Measure- Methodology.html. NOTE: To access the report, click on the zip file titled Inpatient Psychiatric Facility Medication Continuation Measure. 20
IPFQR Program: FY 2018 IPPS Proposed Rule Proposed Administrative Changes 21
Proposed Administrative Changes: Factors for Measure Removal or Retention CMS proposes to align factors for removal or retention of IPFQR Program measures with those of the Hospital IQR Program. These factors include: Measure removal factors Criteria for determining when a measure is topped-out Measure retention factors 22
Proposed Administrative Changes: Procedural Requirements The current timeframe for making changes to the IPFQR Program NOP is January through August 15 each year. CMS proposes to change submission timeframes for NOPs and withdrawals to prior to the end of the data submission period before each respective payment determination year. Specifically, CMS proposes to accept NOPs and withdrawals any time prior to the end of the data submission period before the payment determination year. 23
Proposed Administrative Changes: Data Submission Requirements Beginning with the FY 2019 payment determination, CMS proposes the following: No longer specify the exact dates of the submission period through rulemaking. This is to avoid contradictory guidance between dates established in the Federal Register and dates established through sub-regulatory guidance. Shift to a 45-day submission period that begins at least 30 days following the end of the collection period. Provide notification of exact dates for the data submission period through a sub-regulatory means, such as on a CMS website and/or on the IPFQR Program ListServe. 24
Proposed Administrative Changes: Extraordinary Circumstances Exceptions (ECE) CMS proposes the following updates the IPFQR Program s ECE policy: Specify that ECE forms can be signed by either the Chief Executive Officer or the designated personnel as listed on the ECE form. Change the ECE request form submission deadline to within 90 days of the date that the extraordinary circumstance occurred. Strive to complete CMS review of ECE requests within 90 days of receipt. If finalized these changes would go into effect beginning with the FY 2019 payment determination for extraordinary circumstances that occur during CY 2018. 25
Proposed Administrative Changes: Request for Information on CMS Flexibilities and Efficiencies The Request for Information is included in this Proposed Rule to support CMS commitment to transform the health care delivery system and the Medicare program by the following means: putting an additional focus on patient-centered care working with providers, physicians, and patients to improve outcomes reducing burdens for hospitals, physicians, and patients improving the quality of care decreasing costs ensuring that patients and their providers and physicians are making the best health care choices possible As CMS works to maintain flexibility and efficiency through the Medicare program, we invite the public to submit their ideas for regulatory, sub-regulatory, policy, practice, and procedural changes to better achieve goals for the program. 26
IPFQR Program: FY 2018 IPPS Proposed Rule Helpful Resources 27
Helpful Resources Proposed Rule Available for Review and Comments The FY 2018 IPPS Proposed Rule is available from the Federal Register website at https://www.federalregister.gov/documents/2017/04/28/2017-07800/medicare-program-hospital-inpatient-prospective-payment-systems-foracute-care-hospitals-and-long. See pages 20120-20130 for proposed updates to the IPFQR Program. CMS will accept comments on the Proposed Rule and input on the Request for Information until June 13, 2017. Submit a comment electronically by either: Clicking on the green button at the top of the proposed rule posted in the Federal Register OR Clicking on http://www.regulations.gov, searching for Hospital Inpatient Prospective Payment Systems, and then clicking on the Comment Now! button next to the rule. 28
Helpful Resources Save the Dates Upcoming IPFQR Program educational webinars: May 2017 Navigating to Success: A Review of the Abstraction Process for the Transition Record Measures June 2017 Keys to Successful FY 2018 Data Submission August 2017 IPFQR Program: FY 2018 IPPS Final Rule 29
Helpful Resources IPFQR Program Manual and Paper Tools CMS recommends that IPFs refer to the IPFQR Program Manual for information pertaining to the IPFQR Program. This document, as well as other helpful resources and tools, can be found at: QualityNet > Inpatient Psychiatric Facilities > Resources (https://www.qualitynet.org/dcs/contentserver?c=page&pagenam e=qnetpublic%2fpage%2fqnettier2&cid=1228772864255) Quality Reporting Center > IPFQR Program > Resources and Tools (http://www.qualityreportingcenter.com/inpatient/ipf/tools/) 30
Helpful Resources IPFQR Program General Resources Q & A Tool Email Support Website Phone Support https://cms-ip.custhelp.com IPFQualityReporting@hcqis.org www.qualityreportingcenter.com (866) 800-8765 Monthly Web Conferences ListServes Hospital Contact Change Form Secure Fax www.qualityreportingcenter.com www.qualitynet.org Hospital Contact Change Form (877) 789-4443 31
Disclaimer This presentation was current at the time of publication and/or upload onto the Quality Reporting Center and QualityNet websites. Medicare policy changes frequently. Any links to Medicare online source documents are for reference use only. In the case that Medicare policy, requirements, or guidance related to this presentation change following the date of posting, this presentation will not necessarily reflect those changes; given that it will remain as an archived copy, it will not be updated. This presentation was prepared as a service to the public and is not intended to grant rights or impose obligations. Any references or links to statutes, regulations, and/or other policy materials included in the presentation are provided as summary information. No material contained therein is intended to take the place of either written laws or regulations. In the event of any conflict between the information provided by the presentation and any information included in any Medicare rules and/or regulations, the rules and regulations shall govern. The specific statutes, regulations, and other interpretive materials should be reviewed independently for a full and accurate statement of their contents. 32