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November 15, 2007

Public Reporting and Accountability Updates

In response to questions from members on a variety of interrelated issues, please find the following addressed in this memo:

Schedule for Public Reporting Initiatives – State and Federal
As many hospitals are working to meet various reporting schedules for public reporting and accountability, CEOs and administrative staff have been challenged by all the various deadlines. To clarify the reporting deadlines of both state and federal reporting, IHA will provide an updated and current schedule on its web site for information for the Consumer Guide, Hospital Report Card, Multi-Drug Resistant Organisms, Hospital Quality Alliance Performance Measurements, and HCAHPS. The information will be posted on Tuesday, November 20 at www.ihatoday.org, click on Issues, click on Quality, and then Click on State Reporting Requirements.

Medicare Resources and "Listening Session" on Present on Admission and Hospital Acquired Conditions
Resources. Medicare has announced the release of a new web site focused entirely on the Present on Admission reporting required starting on all inpatient PPS claims starting January 1, 2008 (with claims rejected starting April 1, 2008 for IPPS cases in which Present on Admission codes are missing). The web site also includes information on the Hospital Acquired Conditions targeted for payment reductions starting October 1, 2008. The web site is located at:  http://www.cms.hhs.gov/HospitalAcqCond and includes information on regulations, reporting, coding, and affected hospitals. (Please remember that the Consumer Guide law requires all Illinois inpatient cases to be coded with Present on Admission starting with January 1, 2008 inpatient discharges. The state requirements for the public reporting are for all payers and all hospital inpatient cases.)

Listening Session On December 17, CMS and CDC will hold a day long Listening Session on Hospital Acquired Conditions (HAC) and Present on Admission (POA) coding. While CMS and CDC will make brief presentations, the purpose of the call is to listen to provider concerns and issues on HAC and work to resolve any obstacles providers are experiencing in implementing POA.

The Listening Session will be held in Baltimore at CMS Central Office and dial in will be available for listening only. Written comments will be accepted following the listening session. Please note that more information will be available soon as the meeting date and information has not yet been published in the Federal Register; however CMS wanted to make sure that providers were aware of this upcoming opportunity.

Over the next couple of weeks, IHA will prepare some background information on the issues raised by providers and submit to CMS for discussion on the 17^th of December. While we have commented at every opportunity on some concerns and issues we have with implementing the POA and HAC, we will also suggest some possible avenues for addressing these issues.

Please hold December 17 for an all day HAC/POA Listening Session.  The Listening Session will be jointly sponsored by CMS and CDC and will be held in Baltimore at the CMS Central Office.  Dial-in will be possible, but will be listen only.  CMS and CDC officials will make brief presentations on various related topics, followed by short verbal comments from the participants.  Written comments will also be accepted following the Listening Session.

The formal announcement of the HAC/POA Listening Session will appear in the Federal Register within the next few weeks, but we're getting the word out now so that stakeholders can plan ahead.  I would encourage you to take advantage of this opportunity to provide input regarding our HAC/POA initiative, as what we learn during this Listening Session will inform next year's rulemaking.

Physician Quality Reporting Initiative
The Physician Quality Reporting Initiative (PQRI) will continue during 2008 on a voluntary basis using the physician claims data as the source for reporting. The number of measurements that physicians can report on has expanded greatly to 119 measurements and includes clinical performance measurements and structural measurements, such as adoption and use of various health information technology approaches.

For a summary of the PQRI 2008 voluntary initiative, please refer to the CMS document at http://www.cms.hhs.gov/PQRI/downloads/2008PQRIMPFSSummary.pdf. While we know that hospitals are not directly affected by physician reporting under PQRI, there are some overlapping measurements with PQRI and HQA and many hospitals are interested in staying current with physician clinical practice standards and measurements.

Medicare Hospital Quality Alliance (HQA) Warehouse Problems
As reported last week in a memo to our members, the problems with processing of data and providers getting timely feedback is continuing at the Hospital Quality Alliance warehouse. The deadline of November 15 for HQA performance measurements has been extended to the end of the day on Tuesday, November 20.

IHA is continuing to voice hospital concerns on this issue and we are looking forward to CMS announcing some remedies shortly to address the problems. For an update on IHA activities on this issue, please refer to memo of November 8 (click here).

Joint Commission Technical Errors on Recent Report
On Wednesday, November 14, Joint Commission announced some errors in their recent report released entitled, Improving America’s Hospitals. IHA has updated its information contained in our memo in response to the errors in the Joint Commission report. IHA’s updated memo and notice from Joint Commission can be found by clicking here.

IHA will continue to keep you updated on developments as we know these are very challenging times with so many initiatives occurring quickly and simultaneously.

Wishing you and your loved ones a happy and blessed Thanksgiving!

Staff Contact: Pat Merryweather