Initial Thoughts on the CMS IPPS NPRM: A Public Health Perspective

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Initial Thoughts on the CMS IPPS NPRM: A Public Health Perspective

I have seen several pretty good summaries of the recently release Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rule ...

I have seen several pretty good summaries of the recently release Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program (one from AMIA, one from CDC). Here are just a few additional tidbits I picked out of the NPRM.

Of course, this document is written like stereo instructions so I welcome any corrections or comments to my interpretation of what’s in the rule. I put page numbers (from final FBO version referenced above which has just been released) where relevant in parenthesis.

And I apologize in advance as much of what’s here is cryptic to anyone who has not been exposed to this before and I don’t make much of an attempt to explain the context (or even the acronyms).

  • The proposed changes apply to Eligible Hospitals (EH) and Critical Access Hospitals (CAH) under the Medicare program only, as well as “dual-eligible” hospitals who participate in both the Medicare and Medicaid incentive programs. States are able to request from CMS that their Medicaid programs be allowed to adopt these revised guidelines (20519), but CMS mentioned that they thought that few would do so as the program is winding down. Though in some spots in the NPRM it claims that there are sections relevant to Eligible Professionals (EP) I could not find anything explicit to EPs in the rule, other than the requirement that everyone use 2015 CERHT starting in CY2019 and a question to commenters about whether CMS should extend these rules to EPs (20537).
  • The NPRM proposes to reduce the public health measures from three to two, Syndromic Surveillance (SS) plus one other from a list. I could see no real clear or compelling reason offered in the NPRM other than the general “too burdensome on providers” explanation. (20535-6)
  • Now, I like SS as much as the next guy, but I could also find no compelling reason in the NPRM to single out SS for special treatment (20535).
  • CMS stated their intent to remove public health measures altogether for CY2022 and beyond (20536).
  • In a number of places, the NPRM mentions TEFCA (20537, 20457, 20550) and USCDI (20457), wondering whether participation in these initiatives as they develop should supplement or replace some of the measures in the program.
  • I saw some changes to the 90/10 matching program slipped in, including increases in some of the contract thresholds that require CMS pre-approval which I think is a good thing (20543), as well as complete phase-out of the 90/10 program by 9/30/2022 which perhaps is not (20544).

Wow. So some questions come to mind immediately:

  • Is public health OK with the reduction in the number of measures, and the preference for SS reporting?
  • Is public health OK with a CMS direction to eliminate public health measures altogether should the program continue past 2022?
  • Is public health prepared for the elimination of the 90/10 matching program by 2022?

Would love to know if others interpret this stuff the way I do, and if these are the right questions around which to formulate some comments in response to CMS.