Request for Information
On April 14, 2017, the Centers for Medicare & Medicaid Services (“CMS”) issued the 2018 Inpatient Prospective Payment System (“IPPS”) proposed rule including a Request for Information (“RFI”). The overarching message from CMS is to seek comments to the proposed rule and through the RFI that will advance patient-centered care.
In the midst of uncertainty around our healthcare system, it appears CMS remains on track to develop policies and rules to shift care to “quality” of care and not “quantity.” To do so, CMS issued the RFI to spark a national discussion for proposals on:
- Payment system redesign
- Eliminating or streamlining reporting
- Monitoring and documentation requirements
- Operational flexibility
- Feedback mechanisms and data sharing
- How CMS issues regulations and policy
In assessing the areas above and any other areas of opportunity, hospitals should consider factors such as: decreasing administrative burdens on providers and patients; increasing quality of care; decreasing cost; increasing accessibility; simplification and effectiveness. The overall goal is to provide CMS with ideas/proposals that can inform policy, practice and procedural changes to eventually make healthcare in America simpler, more accessible and effective. CMS asks that all proposals be concise and include data and specific examples where possible. All submissions are due by June 13, 2017.
In addition to the RFI, hospitals may want to consider submitting comments on 2 key areas of the proposed rule:
- Hospital-Acquired Conditions (HAC) Reductions Program: CMS seeks comment on:
- Additional measures for future adoption
- Accounting for social risk factors
- Accounting for disability and medical complexity in the CDC NHSN[1] measures
- Updates to the Extraordinary Circumstance Exception policy
- Hospital Readmissions Reduction Program: CMS proposes to asses penalties based on hospital performance relative to other hospitals with similar proportion of patients dually eligible for Medicare and full benefits Medicaid. CMS seeks comments on:
- Methodology for calculating proportion of dual-eligible patients
- Methodology for assigning hospitals to peer groups
- Payment adjustment formula calculation methodology
[1] Centers for Disease Control and Prevention National Healthcare Safety Network