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Texas Hospital Association
Quality & Reimbursement:
The New Payment World
Kenneth M. Davis, M.D.
Chief Medical Officer
San Antonio Methodist Healthcare System
Gregory N. Etzel
Partner
King & Spalding LLP
Introduction
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Who would oppose a quality-based payment
system…?
Introduction
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But there are challenges…
Today’s Agenda
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We seek to address the following questions faced
by hospitals:
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How did we get here?
What is being measured?
How can a hospital determine where it stands and how
it will get paid?
What should be its operational goals to maximize
reimbursement?
How can resources be allocated to achieve these goals?
Evolution of Medicare as a Purchaser
Cost reimbursement
― rewards furnishing more services
• Prospective payment
― incentives for efficiency
• Value based purchasing
― adds incentives for quality
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I. Brief History
Medicare Hospital Inpatient Quality Reporting
Program (a/k/a IQR Program or RHQDAPU)
― Medicare Modernization Act of 2003, section
501(b) (implemented in FY 2005 IPPS Final
Rule)
― Deficit Reduction Act of 2005, section 5001(a)
(implemented in FY 2007 IPPS Final Rule)
• 2.0 percentage point reduction to base PPS
payment rate per discharge for failure to report
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I. Brief History
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Measures and data listed on Hospital Compare
website
― Also QualityNet website for providers
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HHS 2007 report to Congress regarding internal
CMS deliberation on value-based purchasing
program (would have replaced IQR)
II. Where We Are Now
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PPACA
― Section 3001(a) (becomes 42 U.S.C. 1395ww(o)
― Requires HHS to establish VBP program
beginning with payments for discharges
occurring on or after October 1, 2012
― Funded through reductions in base operating
DRG per discharge payment reductions
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1% in FY2013, 1.25% in FY2014, 1.5% in FY2015,
1.75% in FY2016, and 2% for FY2017 and each
subsequent year
Estimated pool for FY 2013 = $850mm
Final Rule published May 6, 2011
III. Hospital Value Based Purchasing
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Set aside a pool from existing Medicare PPS dollars
Redistribute the pool among PPS hospitals based on
their performance
― as compared to other hospitals
― as compared to each hospital’s prior performance
Create incentives to improve quality
Should be budget-neutral in the aggregate
Who Participates in VBP?
All “subsection (d) hospitals”
• Exempt or excluded hospitals
― Payment reduction under IQR
― Cited for deficiencies
― Puerto Rico & Maryland (?)
― IPPS-excluded hospitals
― Need to have at least 4 quality measures to
participate and at least 10 cases per measure +
100 HCAHPS surveys
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The VBP in FY 2013
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Five aspects
― 1. The Measures
― 2. The Performance Period
― 3. The Performance Standards
― 4. The Score
― 5. The Payment
VBP Measures
By statute, the measures in the following categories
must be included in the VBP program: AMI, heart
failure, pneumonia, surgeries, HAI, and HCAHPS
• Must be listed on HospitalCompare for at least one
year prior to use
• Started with 45 measures, ended up with 12 process
measures + HCAHPS in the Final Rule
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VBP Clinical Process Measures for FY2013
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AMI-7a - Fibrinolytic Therapy Received Within 30 Minutes of Hospital Arrival
AMI-8a - Primary PCI Received Within 90 Minutes of Hospital Arrival
HF-1 - Discharge Instructions
PN-3b - Blood Cultures Performed in the Emergency Department Prior to Initial Antibiotic
Received in Hospital
PN-6 - Initial Antibiotic Selection for CAP in Immunocompetent Patient
SCIP-Inf-1 - Prophylactic Antibiotic Received Within One Hour Prior to Surgical Incision
SCIP-Inf-2 - Prophylactic Antibiotic Selection for Surgical Patients
SCIP-Inf-3 - Prophylactic Antibiotics Discontinued Within 24 Hours After Surgery End
Time
SCIP-Inf-4 - Cardiac Surgery Patients with Controlled 6AM Postoperative Serum Glucose
SCIP-Card-2 - Surgery Patients on a Beta Blocker Prior to Arrival That Received a Beta
Blocker During the Perioperative Period
SCIP-VTE-1 - Surgery Patients with Recommended Venous Thromboembolism
Prophylaxis Ordered
SCIP-VTE-2 - Surgery Patients Who Received Appropriate Venous Thromboembolism
Prophylaxis Within 24 Hours Prior to Surgery to 24 Hours After Surgery
Patient Experience Measures for FY2013
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HCAHPS - Hospital Consumer
Assessment of Healthcare Providers
and Systems Survey
― Communication with Nurses
― Communication with Doctors
― Responsiveness of Hospital Staff
― Pain Management
― Communication about Medicines
― Cleanliness and Quietness of
Hospital Environment
― Discharge Information
― Overall Rating of Hospital.
The Performance Period
For process measures and HCAHPS, July 1, 2011March 31, 2012 for FY 2013
• Compared to performance during baseline period
of July 1, 2009 through March 31, 2010 (FY 2013)
• For future measures, performance period will begin
1 year from the time they are added to Hospital
Compare
― HAC & AHRQ measures will begin March 3,
2012
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Performance Standards
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Threshold = median of hospital performance (50th
percentile) during baseline period
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Benchmark = mean of top decile of hospital
performance during baseline period
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No minimum performance standard
The Score
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Three-Domain Performance Scoring Model
― Only two active in FY 2013
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Points for both achievement and improvement
Achievement score for process measure
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Here’s the formula:
[9 X ((performance period achievement threshold) / (benchmark - threshold))] + 0.5, then
round to nearest whole number
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The simpler version is simply that you get 0 to 10
points based on where your performance falls
between the threshold and the benchmark
Achievement scoring
10 points for meeting or exceeding the benchmark
• 0 points for performing below threshold
• 1-9 on a linear scale between the threshold and
benchmark
• Some benchmarks are 100%
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Improvement scoring
Similar formula to achievement score
• 0-9 points
• 0 for below baseline score
• 1-9 points on a linear scale if above baseline score
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Example of scoring
Another example
The VBP “Compression Problem”
The VBP “Compression Problem”
11 of the 12 clinical measures have very little space
between the threshold and the benchmark
― benchmarks > .90 & thresholds >.99
― E.g. SCIP-Inf-2- Threshold = .9766; Benchmark
= 1.0
• This compression means that very small
differences in performance generate large
differences in scores
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2013 Clinical Process of Care MeasuresThreshold and Benchmarks
Measure ID
AMI-7a
AMI-8a
HF-l
PN-3b
PN-6
SCIP-Inf-l
SCIP-Inf-2
Measure Description
Threshold
Benchmark
Fibrinolytic Therapy Received
Within 30 Minutes of Hospital
Arrival
Primary PCI Received Within 90
Minutes of Hospital Arrival
0.6548
0.9191
0.9186
1.00
Discharge Instructions
0.9077
1.00
Blood Cultures Performed in the
Emergency Department Prior· to
Initial Antibiotic Received in
Hospital
Initial Antibiotic Selection for
CAP in Immunocompetent Patient
0.9643
1.00
0.9277
0.9958
Prophylactic Antibiotic Received
Within One Hour Prior to Surgical
Incision
Prophylactic Antibiotic Selection
for Surgical Patients
0.9735
0.9998
0.9766
1.00
2013 Clinical Process of Care MeasuresThreshold and Benchmarks (cont.)
Measure ID
Measure Description
Threshold
Benchmark
SCIP-Inf-3
Prophylactic Antibiotics
Discontinued Within 24 Hours
After Surgery End Time
0.9507
0.9968
SCIP-Inf-4
Cardiac Surgery Patients with
Controlled 6AM Postoperative
Serum Glucose
0.9428
0.9963
Surgery Patients with
Recommended Venous
Thromboembolism Prophylaxis
Ordered
Surgery Patients Who Received
Appropriate Venous
Thromboembolism Prophylaxis
Within 24 Hours Prior to Surgery
to 24 Hours After Surgery
Surgery Patients on a Beta
Blocker Prior to Arrival That
Received a Beta Blocker During
the Perioperative Period
0.95
1.00
0.9307
0.9985
0.9399
1.00
SCIP-VTE-1
SCIP-VTE-2
SCIP- Card-2
Example of Compression Problem
Example
Measure
Threshold
Benchmark
SCIP-Inf-2
.98
.99
• 3 possible achievement scores - 0, 1, 10
• If a hospital’s score drops from .99 to .97, points
drop from 10 to 0
• Problem is intensified for hospitals with fewer
cases per measure (min. is 10)
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2013 Clinical Process of Care Measures100% Compliance
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6 of the 12 measures require 100% compliance to
receive the full 10 points
― No room for error
― Increases possibility of losing 10 points for
missing just one or two cases
― Compliance with a measure is not always
medically indicated or feasible (e.g., if a patient
is discharged against doctor’s orders).
HCAHPS Scores
Must report minimum of 100 surveys
• Eight dimensions are weighted equally
• Achievement - 0-10 points
• Improvement - 0-9 points
• Formulas are similar to process scores
• Can also achieve points for consistency
• Total = sum larger of achievement or improvement
for each measure + consistency score
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HCAHPS Scores -- Consistency
Purpose is to encourage higher performance across
all HCAHPS dimensions
• Promote wider systems changes within hospitals to
improve quality by offering hospitals additional
incentives
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HCAHPS Scores -- Consistency
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Calculation of Consistency Points:
― If all dimension rates are greater than or equal to
the Achievement Thresholds:
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If any individual dimension rate is less than or
equal to the worst-performing hospital
dimension rate from the Baseline Period
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20 Consistency points (Maximum)
0 Consistency points
If the lowest dimension rate is greater than the
worst-performing hospital’s rate but less than the
Achievement Threshold:
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0-20 Consistency points awarded based on formula
Normalizing scores
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Will only use measures that apply to the hospital
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Convert to percentage of total points available
Total score
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70% clinical process of care
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30% HCAHPS
The Payment
The payment works as an adjustment to base
operating DRG per discharge payment
― Remains unclear how VBP interacts with
payments for DSH, IME, outliers
• Budget neutral
• CMS’s impact analysis shows that:
― top 95th percentile hospitals will receive as much
as 1.575% in VBP payment
― 5th percentile hospitals will receive as little as
0.434% in VBP payment
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Payment Exchange Function
CMS looked at several possibilities
• Linear, cube, logistic
• For FY 2013, exchange function will be linear
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Other Matters
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Publication
― Notice of estimated incentive payment through
QualityNet at least 60 days prior to October 1,
2012
― Score released on November 1, 2012 with 30
days for review
― Actual VBP payment amount not entered into
claims processing system until January 2013
― Aggregate VBP program info published on
HospitalCompare
Other Matters
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Appeals
― Very limited review rights
― May appeal calculation of scores and
performance assessment
― Left for future rulemaking
IV. VBP in FY 2014 and beyond
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Adding outcome measures- 3 30-day mortality measures
(AMI, HF, Pneumonia), 2 AHRQ composite measures, 8
HAC measures
Performance period will be July 1, 2011-June 30, 2012 for
outcome measures
Future measures can be added after being listed on
HospitalCompare for at least one year
Proposed subregulatory process for adding and retiring
measures
― Rejected in Final Rule (preserves notice-and-comment)
― Measures may be adopted for IQR and VBP at the same
time
VBP in FY 2014 and beyond
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Starting FY 2014, VBP program will include efficiency
measures (Medicare spending/beneficiary)
― In the 2012 IPPS proposed rule, CMS proposed to use
claims data to measure all Medicare Part A and Part B
payments for each beneficiary discharge during an
“episode.”
― “Episode” = 3 days prior to an inpatient PPS hospital
admission through 90 days post hospital discharge.
― Base period = May 15, 2010 - Feb. 14, 2011
― Performance period = May 15, 2012 - Feb 14, 2013.
― Scoring would be similar to other VBP measures.
Preparing for VBP
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Know where your hospital stands on each selected
measure for the baseline period and identify which
measures have the best rate of return.
― For example, if a hospital was at the benchmark for a
compressed measure in its baseline period, then a slight
percentage change in score on that measure for the
performance period could cause the hospital to lose 10
points (if it drops below the compressed threshold)
― On the other hand, it could take a very large percentage
improvement to pick up less than 9 points, as an
improvement score, on a measure where the hospital
was well below the threshold for the benchmark period
― In that scenario, it may make sense to play defense first,
before devoting resources to improvement on the latter
measure
Preparing for VBP
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Understand how discharge volume by measure
factors into the VBP score
― Each clinical performance measure has an equal
weight.
― An orthopedic hospital’s great performance on
clinical process indicators in hundreds of
surgical cases could, therefore, be offset by
missing performance indicators in a handful of
heart failure cases.
V. Hospital Acquired Conditions
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Section 1886(d)(4)(D) requires hospitals to furnish coding
information on claims indicating certain conditions
“present on admission” to prevent Medicare payment for
certain hospital acquired conditions
― CMS identified 8 HACs in the FY 2008 IPPS rule
unless there is documentation supporting that the
condition was present on admission
― In FY 2009 two categories were added and refined
codes on the HACs list
― FY 2010 and 2011 contained no new or withdrawn
categories
V. Hospital Acquired Conditions
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PPACA reduces payments 1% to hospitals that rank
in the top quartile of hospital acquired condition
(HAC) rates
― Cumulative effect with other HAC and quality
payment adjustments
― Expansion to Medicaid populations and
conditions as of July 1, 2011
VI. Readmissions Reduction Program
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PPACA imposes financial penalties on hospitals
with high readmission rates
― Performance based on 30-day readmission
measures under the Medicare pay-forperformance program for heart attack, heart
failure and pneumonia
VII. Bundled Payments Initiative
VII. Bundled Payments Initiative
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Recent “Bundled Payments for Care” initiative
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Acute, Post-Acute, and combinations of the two
Hospitals propose discounts from fee for service amounts and
keep additional savings gained from care management
Gainsharing opportunities
Responsibility for certain post-episode costs
Applications being sought by CMS for voluntary participation
Less restrictive than ACO
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Opportunity for Hospitals to share in gains from improved
care management
― Implementation of quality measures
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The future of Medicare reimbursement…
Questions…
Gregory N. Etzel
Partner
King & Spalding LLP
713-751-3280
[email protected]