CMS FY22 IPPS Final Rule

Big News:  Acceleration from Claims to Clinical Data to Measure Patient Safety 

Twenty-four hours ago the Center for Medicare and Medicaid Services (CMS) released the FY2022 Inpatient Prospective Payment System (IPPS) Final Rule governing payment for the inpatient setting.

The significance is two-fold. First, this is a landmark promulgation of some of the first EHR-based hospital harm measures, which use data elements from the EHR to identify potential harm – which are also called “triggers” by those who have developed and published on this method, resulting in validation and evidence for this approach.

Second, CMS announced that the legacy claims-based PSI-90 measure would no longer be used for safety-related reimbursement for the Hospital Value-based Purchasing (HVP) program. This also suggests a significant shift away from the claims-based PSI-90 to a trigger-based approach for identifying and measuring patient harm that is more accurate, timely, and therefore more actionable – in contradistinction to the claims-based PSI-90.

Let’s take a deeper dive by reviewing the below in CMS’ own words.

Excerpt from IPPS final rule

Hospital VBP Program: Adios PSI-90

“We continue to consider patient safety a high priority, but…we believe removing this measure…will reduce the provider and clinician costs associated with tracking duplicative measures across programs. …Accordingly, for the previously discussed reasons, we proposed to remove the CMS PSI 90 measure from the Hospital VBP Program beginning with the FY 2023 program year.” (IPPS Final Rule – Centers for Medicare and Medicaid Services, August 13, 2021, Vol. 86, No. 184, p. 45277)

Hello, EHR-based Safety Measures…

“In addition, as part of our commitment to patient safety, we are developing new digital quality measures that use data from hospital EHRs that would assess various aspects of patient safety in the inpatient care setting. For example, two recently developed measures, Hospital HarmSevere Hyperglycemia eCQM (NQF #3533e) and Hospital Harm-Severe Hypoglycemia eCQM (NQF #3503e) have been proposed and are being finalized for the Hospital IQR Program…” (CMS, August 13, 2021, p. 45278)

…And, More to Come!

“In addition to finalizing the Severe Hyperglycemia and Severe Hypoglycemia patient safety measures in this rulemaking cycle, we will also consider a composite harm measure which includes several patient safety and harm measures when all other harm measures such as pressure injury, falls with injury, acute kidney injury, and medication related bleeding are fully developed.” (CMS, August 13, 2021, p. 45279)

What This Means

What does all this mean? Here are Pascal’s suggested takeaways:

  1. Accept the New Patient Safety. Trigger-based adverse event detection using EHR data elements is here to stay. Research has validated and continued to validate this method for decades. Large health systems have shown this method works at scale, delivering both clinical and financial value – beyond any compliance considerations.
  2. Prepare by Deploying Now. As Pascal wrote last year in its inaugural Virtual Patient Safety (VPS) white paper released in August 2020, operationalizing the method and technology underlying VPS – which is commercially deploying triggers and more – results in a “volume, velocity, and variety” for which most even sophisticated health systems are not prepared, leave alone have ever encountered. This method is significantly different in kind and not just degree, and “walking before running” is advisable to understand how to properly handle this volume, velocity, and variety of data. CMS is moving.
  3. Leverage Your Investment. There is no question that compliance requirements in patient safety are changing based on the above. Consequently, health systems will inevitably have to invest in complying with this new method. Large bellwether health systems have also shown that the trigger-based adverse event identification method deployed at scale identifies 10x the level of serious harm as compared to voluntary event reporting (even at hospitals with strong reporting culture) and, of that greater share of preventable harm found, reduced all-cause harm at levels ranging from 25% to 60%+. Therefore, deploying a solution such as Pascal’s VPS will position health systems not only to comply – which most will assume correctly does not necessarily improve operations – but also to improve outcomes, resulting in reduction in both patient harm and related cost.

A Parting Suggestion

Finally, it will also be most cost-effective and least clinically disruptive to deploy a solution that addresses all-cause harm – i.e. the full range of potential adverse events – with the capability of adding AE identification capability across the whole waterfront of harm using a trigger-based method.

This is in contrast to deploying a hypoglycemic-only solution to address the hypoglycemic measure, and doing similarly for each adverse event type. That will prove most expensive, yielding a suboptimal financial return. More importantly, that incremental, step-wise tactical approach – so common in patient safety – will fail to achieve a comprehensive, systematic, programmatic, and extensible solution that is able to fulfill regulatory compliance and improve clinical operations – all the while evolving with CMS regulatory requirements in patient safety. [/fusion_text][/fusion_builder_column][/fusion_builder_row][/fusion_builder_container]