Life Science Compliance Update

May 31, 2017

CMS Hospital Quality Star Ratings Update

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We continue to monitor the CMS hospital quality star ratings on its Hospital Compare website. The overall star ratings are based on 64 quality measures grouped under three process categories—effectiveness of care, efficient use of medical imaging, and timeliness of care—and four outcomes categories: mortality, patient experience, readmissions, and safety of care. Few hospitals, even among the nation’s best, receive a five-star rating.

Recent Data

According to recent CMS star-rating data as reported by the Advisory Board:

Out of 3,629 hospitals eligible for a rating:

83 hospitals received a five-star rating;

946 received a four-star rating;

1,794 received a three-star rating;

694 received a two-star rating; and

112 received a one-star rating.

CMS did not assign star ratings to 969 hospitals for which it lacked sufficient data.

This clustering around the median rating is similar to what we have seen with other programs like the value-modifier. Does CMS create algorithms to create this distribution? A slight edge toward the bottom for the “underperforming” groups, and a small amount who “win” at the top? Something we will monitor going forward.

Ratings continue to unfairly punish “poor” hospitals

As we wrote earlier this year, the star rating system rewards hospitals that serve mostly affluent patients and punishes those serving the poor. Research by Bloomberg BNA compares star ratings of hospitals, indicating a correlation between high star ratings and high household income, and a corresponding correlation between low ratings and low income. Critics of the rating system point out that low-income patients are more likely to have difficulty accessing transportation for both routine primary care and post-discharge follow-up care. There are also consistently low ratings of academic medical centers, which are generally considered among the nation’s best hospitals and which are often located in low income urban areas. 

Data reliability questioned in different rating system

As has been reported, in the search for hospital quality measures that matter, all kinds of rating systems are coming under scrutiny, including those used by the Leapfrog Group, a nonprofit advocate of quality and safety in healthcare.

A study from the University of Michigan concludes that the group's Safe Practice Score (SPS) produces different results than those used by Medicare's Hospital Compare to track common complications and readmissions.

The Leapfrog findings "skew toward positive self-report[ing]," according to the study, which appeared in the journal Health and was entitled "Dissecting Leapfrog."

Plenty of problems with the CMS system, too

As Health Affairs reported last year, the structure of the CMS program has problems, too. They note that a single score to describe hospital quality is probably not useful for consumer. “Given that the quality for different types of care can vary widely within a single institution, it is unlikely that a single summary score would accurately represent the quality of care for all conditions or procedures at one hospital.

To construct the summary star scores, some fairly complex statistical calculations are performed, which essentially use rank order performance on individual measures, weighted by importance to come up with a summary score. The end result is a distribution of summary scores that approximates a bell-shaped curve with 48 percent of hospitals assigned 3-stars; about 3 percent assigned each 1- and 5-stars, and the rest 2- or 4-stars.”

But there are many problems with using a curve. Health Affairs continues: “First, it implies a meaningful difference in performance when there might not be one. For many of the individual measures from which the summary score is derived most hospitals are no different than the national average. Second, it implies that many stars equal high quality and few stars low. Regardless of whether quality across hospitals is uniformly high, low, or average, the curve will distribute hospitals across the 5-stars. Consider the measures reported in the ‘effectiveness of care’ domain. The average national score is over 92 percent for most of the measures; for several it approaches 100 percent. There is little clinically meaningful difference in scores across hospitals and the performance is uniformly high.”

May 19, 2017

Medicare Cuts in the Future of HACRP Hospitals

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As has been noted, CMS named 769 hospitals that will face Medicare payment cuts in fiscal year (FY) 2017 under the Hospital-Acquired Condition Reduction Program (HACRP), which for the first time considered rates of infection from antibiotic-resistant bacteria in its calculations. The HAC Reduction Program requires the Secretary of the Department of Health and Human Services to adjust payments to applicable hospitals that rank in the worst-performing quartile of all subsection (d) hospitals with respect to risk-adjusted HAC quality measures. These hospitals will have their payments reduced to 99 percent of what would otherwise have been paid for such discharges. In the FY 2017, HAC Reduction Program, hospitals with a Total HAC Score greater than 6.5700 are subject to a payment reduction.

CMS on HACRP

From Modern Healthcare: “Our goal is for all hospitals to improve,” and roughly half did improve enough to escape the bottom quartile, said Dr. Patrick Conway, the CMS' deputy administrator and chief medical officer. Federal data on quality measures released earlier this month by the Agency for Healthcare Research and Quality also showed that between 2010 and 2013, progress was made in reducing patient harm and preventing avoidable deaths, he said.

Reaction

The Advisory Board collected reaction from stakeholders. Some noted that hospitals cannot fully control antibiotic-resistant infections that occur in their facilities. Louise Dembry, a professor at the Yale School of Medicine and president of the Society for Healthcare Epidemiology of America, said, "The reality is we don't know how to prevent all these infections."

Moreover, some critics take issue with the way HACRP assesses penalties. Because the program penalizes the 25 percent of hospitals that perform worst overall, in some cases a hospital is penalized even though it has reduced its rate of avoidable complications. Nancy Foster, vice president for quality and patient safety at the American Hospital Association, said, "The HAC penalty payment program is regarded as rather arbitrary, so other than people getting upset when they incur a penalty, it is not in and of itself changing behavior"

Example from Emory

Three Emory-affiliated hospitals were fined for high rates of hospital-acquired conditions for fiscal year 2017. Emory University Hospital Midtown (EUHM) is being fined for the third consecutive fiscal year, and Emory Johns Creek Hospital (EJCH) for the second consecutive fiscal year. Emory University Hospital (EUH) is being fined for a second fiscal year, the first instance occurring in 2015.

But Emory’s response is worth considering. Director of Media Relations of Emory Healthcare Janet Christenbury wrote in a statement that the ratings inaccurately compared hospitals because they are “based on methodologies that often do not sufficiently take into account the differences in patient populations and the complexity of conditions that certain hospitals treat.”

Teaching hospitals, such as Emory’s Midtown facility, are unique because they conduct various common and complex procedures and provide clinical education and training to current and future medical providers, Christenbury said. Consequently, there is more data to report to CMS in comparison to other facilities that treat patients with limited specializations or more common conditions, Christenbury added.

April 11, 2017

Open Payments Starts Review and Dispute…On A Saturday

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With the close of Open Payments submission just behind us, the Centers for Medicare & Medicaid Services (CMS) plans to publish the Open Payments Program Year 2016 data and updates to the 2013, 2014, and 2015 program years on June 30, 2017.

As such, the review and dispute period for the Program Year 2016 Open Payments data publication begins on Saturday, April 1, 2017 and will last until Monday, May 15, 2017. Physicians and teaching hospitals must initiate their disputes during this 45-day review period in order for any disputes to be addressed before the June 30th publication.

Physician and teaching hospital review of the data is voluntary, but strongly encouraged by CMS. While the opportunity for physicians and teaching hospitals to dispute any data associated with them expires at the end of the calendar year in which the record is published, the disputes must be addressed during the 45-day review and dispute period, ending on May 15th, in order to be reflected in the June 30th publication. 

To those who have never registered in the Open Payments system before, you will need to create an account. To do so, make sure you have your National Provider Identifier (NPI) number, Drug Enforcement Agency (DEA) number, and State License Number (SLN). Initial registration is a two-step process and should take approximately 30 minutes: first, you will need to register in the CMS Enterprise Identity Management System (EIDM) and from there, you can register in the Open Payments system.

Physicians and teaching hospitals who registered last year do not need to reregister in the EIDM or the Open Payments system. If the account has been accessed within the last 60 days, go to the CMS Enterprise Portal, log in using your user ID and password, and navigate to the Open Payments system home page.

However, the EIDM locks accounts if there is no activity for 60 days or more. To unlock an account, go to the CMS Enterprise Portal, enter your user ID and correctly answer all challenge questions; you’ll then be prompted to enter a new password. The EIDM also deactivates accounts if there is no activity for 180 days or more. To reinstate an account that has been deactivated, contact the Open Payments Help Desk.

CMS Is Offering a Teleconference on the Review and Dispute Process

Join the Centers for Medicare & Medicaid Services (CMS) on April 13, 2017 for an informative session on the Open Payments Review and Dispute process.

This National Provider Call will provide physicians and teaching hospitals an opportunity to learn about the review and dispute process, including how to access the Open Payments system to review the accuracy of the data submitted before it is published on the CMS website.

A question and answer session will follow the presentation. Topics covered will include: overview of the Open Payments Program; Program Timeline; Registration Process; and critical deadlines for physicians and teaching hospitals. 

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