MHA Today | April 22, 2016

April 22, 2016
MHA Today: News for Healthcare Leaders

MHA Today is provided as a service to members of the Missouri Hospital Association. Additional information is available online at MHAnet. Connect with us on LinkedIn.


Insights


Herb Kuhn, MHA President & CEO

On Wednesday, the Centers for Medicare & Medicaid Services announced a delay to the “star rating” system for hospitals that was to be launched on Hospital Compare yesterday. More than half of each chamber of Congress had urged delay, including the majority of Missouri’s delegation. It was the right decision for several reasons.

CMS is under significant pressure to publish a star rating system for hospitals. I understand their urgency.. As CMS Deputy Administrator during the final year of the previous administration, I know there is significant pressure to complete legacy-related work before handing the keys to the next set of leaders. Considering the sea change in health care throughout the last six years — including, but not limited to the movement toward value-based care — the determination to finalize the program must be immense. Nonetheless, there’s a responsibility to get it right. And, we’re not there yet.

Earlier this year, we released research on the influence of sociodemographic status on outcome-based quality measures. Our analysis reinforced the connection between community setting and health outcomes, and added to the evidence that an individual’s ZIP code may be as powerful a determinant of heath as their genetic code. Just this month, we followed with research on diabetes that found dramatic differences in health status and life expectancy in communities separated by only a few miles. We’re not alone. Academic journals, the National Quality Forum and others have been expanding the pool of research on this topic as well.

Recently, CMS announced that it was not adopting additional adjustments for SDS to its methodology for readmissions, even though a growing body of evidence suggests these factors can influence a hospital’s performance. As we’ve pointed out in the past, CMS does recognize the influence of these factors — they are being integrated into risk adjustment for Medicare Advantage. However, they have failed to integrate them into hospital-care risk adjustment. Absent these adjustments, the star rating system compounds the differences between hospitals by including the unadjusted data in their ratings methodology. It’s a case of adding insult to injury.

From the beginning, our research goal has been to build a system on better data. When we relaunched Focus on Hospitals in February, we provided consumers with CMS-adjusted and SDS-adjusted data. Our intent was to drive policy while giving consumers a more accurate reflection of performance. At the same time, we wanted to improve the objectivity of the system, since the CMS “Compare” sites are an important consumer data source and a lever in CMS’ efforts to improve quality through increased transparency. A lack of confidence in the system significantly undermines its value.

Transparency isn’t about winners and losers; it’s about identifying strengths and weaknesses to enable the marshalling of resources to improve performance. Transparency initiatives based on questionable methodological rigor can result in a negative sum game for health care — misinformed decision-making on the part of patients, and investments that chase random variation on the part of providers. An improved methodology will build the confidence needed to allow hospitals — and all providers — to truly use ratings data to better understand where opportunities for improvement exist and how to target scarce resources within clinical settings and the community.

There’s a line from the financial services industry that’s applicable, “past performance does not necessarily predict future results.” Hospital Compare reviews past performance and relies on insufficient data to draw broad assumptions about hospital overall quality. If CMS is serious about star ratings that reflect actual expected performance, they have a lot of work to do between now and July. The delay provides a tremendous opportunity to develop a more accurate rating system. It’s unlikely that the star system will be abandoned, so in the interim, MHA and other stakeholders, will continue to help shape the conversation with timely research and appropriate pressure on decision makers.

The star rating system is intended to be the culinary equivalent of a reduction sauce — where multiple ingredients meld to create a defined, deep flavor. Whether all of the idiosyncratic nuances of hospital quality can be reduced to a scale of one to five is subject to debate. However, any gourmand can attest that a good reduction sauce is about just the right mix of ingredients and time. As they now stand, the star ratings system have neither. The ingredients fail to capture true hospital quality and time is insufficient — as the sun sinks low on the legacy-building horizon for the current administration — to generate depth of flavor of performance.

We know from quality improvement efforts that it usually isn’t a single error that causes a failure in the system. Harm is usually the result of compounded events. Haste creates opportunities for harm. In my final year in the Bush administration, I spent half my time working to get the last elements of our agenda pushed through and half my time working to prevent bad things from happening. As the clock ticks toward January 2017, policymakers must find an equilibrium between a fixed deadline and unfinished business — a balance that ensures they don’t harm the system.

If the goal of Hospital Compare is to provide an accurate representation of hospital quality and value, CMS must rethink its hospital star rating program. Before they try to make the reduction sauce, CMS will need the correct ingredients. Then they'll need to take the time to get it right.

Email me with your thoughts.

Herb Kuhn, MHA President & CEO



Herb B. Kuhn
MHA President and CEO

In This Issue
Legislators Complete State Budget Enactments
CMS Extends Next Generation ACO LOI Deadline
CMS Releases Proposed FY 2017 SNF PPS Rule
CMS Releases Proposed FY 2017 IRF PPS Rule
CMS Releases Proposed FY 2017 Hospice Payment And Policy Updates
Opioids — A Population Health Strategy

Advocate
state and federal health policy developments


Legislators Complete State Budget Enactments

Staff Contacts: Daniel Landon or Rob Monsees

The Missouri General Assembly has completed its enactment of a state budget for the fiscal year beginning July 1, 2016, as well as the “supplemental” budget to address unexpected costs incurred in the current fiscal year. The state constitution mandates the legislative work on the budget be completed by Friday, May 6. By finishing the work early, legislators will be able to review and potentially override gubernatorial vetoes during the 2016 legislative session, which ends May 13. Legislative conference committee negotiations resolved differences between the House and Senate versions of the budget. The final budget maintains open-ended flexibility in the use of hospital provider tax to support hospital Medicaid payments. Medicaid hospital appropriations are in keeping with anticipated spending. Legislative concern about a $250 million supplemental budget request linked to Medicaid did not engender threatened hospital funding shortfalls.

Back To Top


CMS Extends Next Generation ACO LOI Deadline

Staff Contact: Andrew Wheeler

The Centers for Medicare & Medicaid Services has extended the Next Generation Accountable Care Organization letter of intent deadline to Friday, May 20. Questions regarding the Next Generation Model can be directed to NextGenerationACOModel@cms.hhs.gov.

Back To Top


Regulatory News
the latest actions of agencies monitoring health care


CMS Releases Proposed FY 2017 SNF PPS Rule

Staff Contact: Andrew Wheeler

The Centers for Medicare & Medicaid Services released a proposed rule to update the payment rates for skilled nursing facilities for federal fiscal year 2017. The payment update includes a 2.1 percent or $800 million increase over the 2016 payments. The proposed rule also includes information about the new SNF value-based purchasing program scheduled to begin in FFY 2019 and other quality program updates. Comments about the proposed rule are due by 4 p.m. Monday, June 20. MHA has published an issue brief with additional details.

Back To Top


CMS Releases Proposed FY 2017 IRF PPS Rule

Staff Contact: Andrew Wheeler

The Centers for Medicare & Medicaid Services released a proposed rule to update the payment rates for inpatient rehabilitation facilities for federal fiscal year 2017. The payment update includes a 1.45 percent increase. CMS also increased the payment rate to 1.6 percent because of revisions to the outlier threshold. The total amount of increase over 2016 payments are projected to be $125 million. The proposed rule includes updates to the IRF quality reporting program and small revisions to the wage index information used under the IRF program. Comments about the proposed rule are due by 4 p.m. Monday, June 20. MHA has published an issue brief with additional details.

Back To Top


CMS Releases Proposed FY 2017 Hospice Payment And Policy Updates

Staff Contact: Andrew Wheeler

The Centers for Medicare & Medicaid Services released a proposed rule to update the payment rates for hospice providers for federal fiscal year 2017. The payment update includes a 2.0 percent or $330 million increase over the 2016 payments. The proposed rule also includes a 2.0 percent update for the FY 2017 hospice cap, description for the Hospice CAHPS survey, and annual payment update requirements for FY’s 2019 and 2020. Comments about the proposed rule are due by 4 p.m. Monday, June 20. MHA has published an issue brief with additional details.

Back To Top


Quality and Population Health


Opioids — A Population Health Strategy

Staff Contacts: Leslie Porth or Alison Williams

As a participant in the Institute for Healthcare Improvement’s Leadership Alliance, MHA is actively involved in developing solutions to the opioid epidemic through its population health workgroup. Thursday’s IHI podcast profiled a population health-based strategy to address opioid use through four types of patients and four key strategies. The strategy calls for limiting supply through changing prescriber knowledge and practice to addressing the stigma of substance abuse at the community level and engaging multiple stakeholders to meet these challenges. Emergency Department Guidelines for Managing Opioids published in December 2015 are available on MHA’s website to support hospitals and communities in addressing prescribing practices and patient education needs.

Back To Top


Did You Miss An Issue Of MHA Today?


April 21, 2016
Infection Control Bill Advances
Senate Committee Hears Hospital Construction Regulatory Relief Bill
Legislative Amendments Change Nursing Licensure Standards
Legislators Swarm Telemedicine Bill
Congressional Subcommittee Approves Opioid Bills
CMS Releases FY 2017 IPPS And LTCH Proposed Rule
MLN Connects Provider eNews Available
HIDI Hosts Monthly Focus Session Detailing Available Readmissions Reports

April 20, 2016
CMS Delays Star Rating Of Overall Hospital Quality
FRA Reauthorization Bill Advances
House Approves Hospital Helipad Bill
Legislators Enact New Pharmacy Law
CMS Releases MA Quality Data For Racial And Ethnic Minorities
CMS Announces IQR Education Session
CPS Publishes Patient Safety Report
DHSS Issues Funding Opportunity For State-Designated Ebola Assessment Hospitals

April 19, 2016
Majority Of U.S. House And Senate Support CMS Star Rating Delay
MHD Posts Mental Health Crisis Prevention Project 1115 Waiver
CMS Releases FY 2017 IPPS And LTCH Proposed Rule

April 18, 2016
MHA Distributes Analysis Of Medicare’s HAC Reduction Program
WPS Hosts New Rural Health Clinic Billing Teleconference
CMS Publishes Final Rule On Home And Community-Based Services
HIDI HealthStats — Diabetes And Health Equity
CMS Issues Guidance For Labs And Radiology



Consider This ...

Many chronic diseases are preventable. Yet of the adults in Missouri, 65 percent are overweight or obese, 43 percent eat less than one fruit a day, 24 percent eat less than one vegetable a day and 23 percent smoke cigarettes.

Source: Partnership To Fight Chronic Disease