View from the Hill - Proposed FY 2016 IPPS rule barely changes patient safety programs

View from the Hill - Proposed FY 2016 IPPS rule barely changes patient safety programs

August 04, 2015
Jill Rathbun
From the June 2015 issue of HealthCare Business News magazine

On April 17, 2015, the Centers for Medicare and Medicaid Services (CMS) released for comment a proposed rule for FY 2016 to update payments and policies for the hospital inpatient payment system.This is also the proposed rule where the policies regarding the readmissions program, hospital-acquired conditions programs, and the value-based payment program are discussed and any changes proposed.

With the Oct. 1, 2015, implementation date for ICD-10-CM procedure and diagnosis codes causing hospitals and CMS to need to focus on their billing systems and crosswalks for all the codes in these various quality programs from ICD-9-CM to ICD-10, there is very little proposed change in these policies, or expansions for FY 2016.

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This IPPS proposed rule continues the 3% payment reduction for hospitals with high numbers of readmissions, the 1% penalty for hospitals in the worst performing quartile under the hospital-acquired conditions reduction program, and the 1.75% budget neutral pool of bonuses and penalties for hospital value-based purchasing created by an across-the-board reduction to hospital payments. For FY 2016, CMS is proposing that hospitals will have up to 5.75% of their Medicare revenue at “risk” for quality and value-based care activities. Based on current Medicare law, their percentage is set to rise to 6% in FY 2017.

One change that will impact all hospitals, and their numbers associated with the hospital-acquired conditions reduction program, is that CMS is proposing to expand the populations that will be covered by two measures that already exist in the program – central line associated bloodstream infections (CLASB) and catheter associated urinary tract infections (CAUTI) – to patients in select non-intensive care unit sites within a hospital. Previously these measures have applied to those patients in the ICU and CCU.

Parameters for a condition to be included in the hospital-acquired conditions program are that it is high cost, prevalent in the Medicare program, and has evidence-based clinical practice guidelines regarding how to avoid the condition from happening.

With regard to central line-associated bloodstream infections, one of the evidence-based best practices to reduce this complication is the use of ultrasound guidance. Ultrasound guidance of catheterization of the internal jugular vein reduces the rate of catheter-related bloodstream infections by more than one-third (35%).1 Regarding the cost of these infections, the Centers for Disease Control and Prevention estimates that the marginal costs to the health care system of a single catheter-related bloodstream infection is $25,000; attributable mortality is estimated at 12%.2

Comments on these proposed changes to the inpatient quality and value-based purchasing programs, as well as other changes proposed by CMS are due by June 16, 2015, and can be submitted at The final FY 2016 Inpatient Prospective Payment System rule will be released by CMS on or around Aug. 1, 2015.

About the author: Jill Rathbun is managing partner at Galileo Consulting Group, in Arlington, VA. She will be commenting for DOTmed HealthCare Business News magazine on such vital issues for all health care professionals as the implications of the president’s FY 2016 budget, the new makeup of Congress, possible Medicare payment proposals from the Centers for Medicare and Medicaid Services, reports from the Medicare Payment Advisory and more.

1 Karakitsos, et al. “Real-time Ultrasoundguided Catheterization of the Internal Jugular Vein,” Critical Care, November 2006.
2 O’Grady NP, et al., “Guidelines for the Prevention of Intravascular Catheter-Related Infections,” Centers for Disease Control and Prevention, August 2002.

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