AAOS September 5, 2017
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Jacob G. Calcei, MD


ICYMI: CMS Releases Medicare Hospital Inpatient Prospective Payment System Final Rule

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ICYMI: CMS Releases Medicare Hospital Inpatient Prospective Payment System Final Rule

On August 2, 2017, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that updates Medicare payment and polices when patients are discharged from hospitals from October 1, 2017, to September 30, 2018. According to CMS, the final rule relieves regulatory burdens for providers; supports the patient-doctor relationship in healthcare; and promotes transparency, flexibility, and innovation in the delivery of care.

AAOS submitted comments on the proposed rule in June (read them online here), and the final rule reflected many positive developments as a result of AAOS advocacy:

  • Regarding proposed movement of Total Ankle Arthroplasty (TAA) from MS-DRG 470 to MS-DRG 469, CMS announced the agency is reassigning the following procedure codes from MS-DRG 470 to MS-DRG 469, even if there is no major complication or comorbidity reported for FY 2018. CMS is changing the titles of MS-DRGs 469 and 470 to the following to reflect these MS-DRG reassignments:
    • MS-DRG 469: “Major Hip and Knee Joint Replacement or Reattachment of Lower Extremity with MCC or Total Ankle Replacement”; and
    • MS-DRG 470: “Major Hip and Knee Joint Replacement or Reattachment of Lower Extremity without MCC.”
  • On the issue of addressing social risk factors within each of its quality programs, which is an AAOS concern, CMS stated the agency will continue to monitor the work being done by the Assistant Secretary for Planning and Evaluation (ASPE) as part of its study required by the IMPACT Act. In the earlier comment letter, AAOS highlighted that risk stratification and adjustment are equally significant components of valid quality assessment. “Outcome measures are only reliable in a relative sense, as a means to compare baseline and post- care status,” AAOS wrote. “Comorbidities, functional impediments, and cognitive limitations must be accounted for when assessing quality and costs. Importantly, the effects of multiple co-morbidities and social factors are often synergistic. Providers should not be financially penalized when caring for patients with greater needs.”
  • Regarding a proposed change in the “Pain Management” category of the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS), AAOS was pleased to see that CMS is replacing the pain management questions to focus on the hospital’s communications with patients about the patients’ pain during the hospital stay beginning with surveys administered in January 2018. In response to stakeholder feedback, public display of hospital performance data on these refined questions will be delayed for one year so that hospitals may gain more experience with the refined questions.
  • Another positive development in the final rule was that for 2017, CMS announced the agency is modifying the CQM reporting period for EPs in the Medicaid EHR Incentive Program to be a minimum of a continuous 90-day period during calendar year 2017. For 2017, CMS is also aligning the specific CQMs available to EPs participating in the Medicaid EHR Incentive Program with those available to professionals participating in the Merit-based Incentive Payment System.
  • Finally, AAOS was pleased to see CMS is adopting final policies to allow healthcare providers to use either 2014 Edition CEHRT, 2015 Edition CEHRT, or a combination of 2014 Edition and 2015 Edition CEHRT, for an EHR reporting period in 2018. According to CMS, this policy is based on the ongoing monitoring of progress on the deployment and implementation status of EHR technology certified to the 2015 Edition, as well as feedback by stakeholders expressing the need for more time and resources are needed for the transition process.

For more information on the Inpatient Prospective Payment System final rule, visit the CMS website online at: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-items/2017-08-02.html.