IPPS by the Numbers
On December 18th CMS presented a webinar on the Promoting Interoperability Program as applied to Inpatient Prospective Payments. Among the other content the webinar included changes from 2018 to 2019, and from 2019 to 2020. For me this produced a dazzling, and almost comical, conglomeration of rules, current changes in rules, and future changes in rules.
I was inspired to collect some factoids about these many changes. First, there is a new performance-based scoring methodology. The minimal acceptable score is 50. All numerical measures must be reported on in addition to those that are now yes/no such as Security Risk Assessment.
Use of a 2015 ONC compliant EHR is required. Three program measures are removed for 2019, others are renamed. Renaming things is popular but it is hard to see why the new names actually change anything. For 2019 there are four objectives unequally weighted at 10, 40, 40 and 10 points, with two bonus categories of 5 points each available for the first objective. This changes for 2020 when one bonus point category becomes mandatory, with the total 10 points split between the now two categories. The other bonus point category remains. For both 2019 and 2020 Public Health and Clinical Data Exchange involves selecting two of six measures.
There are three exclusions available for 2019 with one Yes becoming a No, and one No becoming a Yes for 2020, thereby there still being three exclusions in 2020 but not the same ones as for 2019. Part of the exclusion issue is whether the EHR vendor has made the necessary product changes to enable compliance. If they ultimately don’t do it a timely manner the hospital pays in points. Clinical Quality Measures are reduced from 16 in 2019 to 8 in 2020.
One of many measures that raises questions is what is now called “Support Electronic Referral Loops by Sending Health Information”. This was previously called “Send A Summary of Care” but perhaps this was too easily understood given that it is in plain English. Here the hospital gets points for sending information but nothing is said about the entity receiving the information such as was it manageable and useful. One can imagine senders being sure to send to earn points with the receiver having the burden of managing what arrives. Another name change from readily understandable to obtuse is from “Provide Patient Access” to “Provide Patients Electronic Access to Their Health Information”. Electronic access of course assumes that the patient has access to such access. It may come as a shock but not everyone in the country has a suitable device or internet availability.
Other related programs have similar changes and proposed changes rolling out. MIPS has 4 categories with unequal weights and some bonus point activities. The provider can be individual or joint. Some exclusions are available. There are 300 MIPS quality measures. There are changes from 2018 to 2019, and from 2019 to 2020. These changes can make the same level of activity better or worse overall, making MIPS somewhat of a scoring game. And CMS just announced that it is soliciting recommendations for “Potential Consideration of New Specialty Measure Sets for the Quality Performance Category and/or Revisions to the Existing Specialty Measure Sets for the Quality Performance Category for the 2020 Program Year of MIPS”.
One thing that is hard to discern from all this is what it actually has to do with the quality of healthcare delivered to the American public. There are certainly arguments as to why an item might seem like a good idea, but this is not the same as proving that it actually matters. And such proof should not be hypothetical or anecdotal. In this same regard it would be nice if Improvement Activities actually reflecting improving something-other than your score.
The compulsion to change things regardless of a proven problem or a proven solution is a disease of the rule makers. I am reminded of a university project accounting report I once received that was all zeros because the project was over. I mentioned to a business official that I finally got an accounting report I could understand. He said if I understood it, it was time to change it.