Post on 31-Dec-2015
description
Dexanne B. Clohan, MDSVP & Chief Medical OfficerHealthSouth
November 14, 2014
IRF Quality Measurement: A Physiatrist’s View
CMS IRF Quality Reporting Program (QRP)QRP Initiated:
(1) new or worsened
pressure ulcers and (2)
catheter-associated
urinary tract infections
New QRP Measures:
(3) Flu vaccines for healthcare personnel
and (4) patients, (5) 30-day,
all-cause unplanned readmission
Future QRP Measures:
(6) MRSA infections(7) CDI infections
What Will Get Measured Next?•Function•Fall rates•Skin Integrity
Reimbursement Effects
All quality data submitted to CMS must meet accuracy and completeness thresholds in order to avoid penalty:
Penalty is theoretically “all or nothing” – failing to submit one of the seven QRP measures accurately and completely will result in payment reduction
Penalty is a reduction to a hospital’s Medicare reimbursement update by 2% for the next fiscal year
October 1, 2012 October 1, 2014 January 1, 2015
2
New Thresholds ImposedIRF PPS FY 2015 Final Rule
• Catheter-Related Infections – 100% Completion – CMS must receive 12
months of data from the NHSN system.
• Pressure Ulcers– 95% Completion – IRF-PAIs must include
required QRP data.– 75% Accuracy – CMS will randomly select
5 patient records from 260 IRF providers.• IRF-PAIs completed January 1, 2014-
September 30, 2014* will be audited for accuracy for FY2016.
*Abbreviated 9 month period a result of CY to FY transition
3
• CMS still adjusting their own documentation requirements• Requires accurate, complete, and consistent documentation
by clinicians• CMS QRP rules go beyond standard clinical practice
Documentation
• CMS revised existing measures• CMS is adding new measures at fast pace
Continued Changes
• Patchwork system created by CMS for reporting is not efficient
• Multiple reporting methods have different timelines and definitions
• Reportable events are rare
Complexity
• Increased proportion of clinicians’ time spent on paperwork• More clinical time being spent on low incidence measuresEffect on Staff
Why is QRP challenging?
4
• Reported through IRF-PAI (Inpatient Rehabilitation Facility – Patient Assessment Instrument)
Based on CMS Fiscal Year (Oct-Sept)– Pressure Ulcers– Patient Influenza Vaccination Rates
• Reported through the NHSN (Managed by the CDC)
Based on Calendar Year (Jan-Dec)– Catheter-related infections– Personnel Influenza Vaccination Rates– Antibiotic-Resistant Infections
• MRSA infections • CDI
• Collected via Claims Data– 30-Day Acute Readmission Rates
Multiple Reporting Methods
5
6
Reportable Events
Clinical Care
Only reportable events should be reported
•Physician diagnosis•Clinical treatment•Billing codes
Meet all criteria and timelines
The QRP Guide: Everything You Need to Know to be CMS Compliant
• A comprehensive and user-friendly document to help manage the task of understanding and complying with this rule
• contains information regarding the prevention, identification, and reporting of QRP measures.
• Compiles guidelines, rules and best practices from all sources involved in the inpatient rehab QRP, including:
7
HealthSouth’s Approach
IRF PPS Rule
CMS training
CDC guidelines
NHSN guidelines
IRF-PAI manual
IRF-PAI transmission
Training
• Clinical & Reporting– On-site meetings– Online HealthStream courses– Training webinars (recorded and posted)– QRP Guide– QRP@HealthSouth.com email address
Who is Involved?
• Chief Nursing Officer and Quality Director ultimately responsible for documentation and reporting
• Infection Control/Wound Care, Employee Health, Human Resources have role in gathering and reporting QRP data
• HIMS staff enter data into IRF-PAI• Medical staff have oversight for
clinical care and medical documentation
9
Data Analysis
• CMS has released limited QRP reports through QIESnet, but data can be monitored via IRF-PAI submissions and NHSN reports
• Strive to improve QRP compliance and clinical quality. Eventually, QRP will shift to pay-for-performance
• Look for ---or create--- benchmarks10
Patient Safety Impact
• Engage staff in prevention of pressure ulcers, CAUTIs, and increase in flu vaccinations with a focus on the patient
• Share the data regarding events, vaccination rates, or the lack thereof!
• Stabilize processes for assessments and documentation in the medical record to allow staff to enhance clinical practice- not just documentation.
Regulatory
Burden
Patient Benefit