Is Data Collection too Burdensome in CMS Final Payment Rule?
"CMS is moving too quickly with these expansions and proposing policies that are ... operationally and administratively burdensome for hospitals to implement."
By - A new 311 page final rule from the Centers for Medicare & Medicare Services (CMS) aims to amend the Medicare hospital outpatient prospective payment system (OPPS) and the Medicare ambulatory surgical center (ASC) payment system.
CMS’s document, which includes a revised comment period, proposes the execution of numerous applicable statutory requirements. The final rule additionally discusses enhanced requirements to the Hospital Outpatient Quality Reporting (OQR) Program and the ASC Quality Reporting (ASCQR) Program.
CMS describes various finalized policies regarding the hospital inpatient prospective payment system. One includes modifications to the two-midnight rule under the short inpatient hospital stay policy.
Another involves a payment transition for hospitals that are no longer classified as being located within a rural area due to new Office of Management and Budget definitions and have yet to be reclassified. Such hospitals, says CMS, are no longer able to maintain their standing as Medicare-dependent, small rural hospitals.
CMS’s final rule also confirms various proposals and addresses a slew of public commentary regarding Medicare regulation changes.
Disapproval for CMS’s proposed hospital reimbursement
Many appear to be in disagreement with CMS’s final rule documentation. Here are some selected highlights of what some have to say within their publicly submitted commentary.
Many across the nation chose to include the following blurb within their commentary:
This rule change would have an unprecedented impact on all of the community blood centers with planned cuts to the Medicare outpatient payment rates for various blood products that range from roughly 25-66% from the previous rates.
With these proposed cuts, payment for outpatient blood transfusion would not even come close to covering the cost of collecting, processing, and distributing safe blood products to save and enhance patient lives.
The entire blood community, including AABB and American Red Cross, is in agreement that the effects of payment rate cuts will be extensive and adverse for hospitals, healthcare organizations, and blood centers alike.
It remains unclear to us how CMS arrived at these reimbursement rates. Community blood centers are already experiencing significant financial challenges at a time when new opportunities to improve the safety of the nation's blood supply through new technology exist. Such advances demand increased investments, which is the opposite of the proposed reductions.
Some expressed support for CMS’s proposed two-midnight rule modifications and its medical review strategy for patient status claims. Although one President and CEO expressed such opinions, he also confirmed within his public commentary that CMS’s final rule still lacks validation:
CMS is moving too quickly with these expansions and proposing policies that are not adequately explained, difficult to validate, and operationally and administratively burdensome for hospitals to implement.
For the upcoming final rule and in future rulemaking, we urge CMS to provide additional rationale and explanation as well as separate impact analyses for any significant policy shift.
Says another organization in general support of CMS’s proposed rule:
We understand and support the continued testing of pain questions in the survey. As CMS continues its work, we encourage you to communicate potential timing for implementation of the ED PEC survey, as this will help hospitals to prepare for participation.
We support CMS’ proposed additions to the Outpatient Quality Reporting Program (OQR) measures, as we believe these measures will help the program measure a wider variety of topics that are important to patients.
While we support the addition of OP-34, Emergency Department Transfer Communication, to OQR for payment year CY 2019, we encourage CMS to consider alternative measures that are less complicated to implement.
Conceptually, we agree that this is an important topic to measure to ensure high quality, well-coordinated care. However, in our work supporting hospitals in collecting this measure, we recognize that data collection is a considerable burden.
