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2024 OPPS Final Rule: Quality Programs

November 22, 2023

Sometimes we buy on time. That may call for making a few installment payments. Our reporting on the highlights of the 2024 Outpatient Prospective Payment System (OPPS) final rule seems to be working out in similar fashion, i.e., in installments. In this third installment on Medicare’s final rule for the outpatient hospital setting, our focus will be exclusively on the quality programs set forth by the Centers for Medicare and Medicaid Services (CMS), effective January 1, 2024.

According to a fact sheet released by CMS, the agency is finalizing changes to the Hospital Outpatient Quality Reporting (OQR) and Rural Emergency Hospital Quality Reporting (REHQR) programs to further its goals of “meaningful measurement and reporting of quality of care in the outpatient setting.”

Outpatient Quality Reporting

The Hospital OQR program is a pay-for-reporting measure that requires hospitals to meet quality reporting requirements. Facilities that fail to meet these requirements will receive a reduction of 2.0 percentage points in their annual payment or fee schedule update.

In the 2024 OPPS final rule, CMS is finalizing modifications of three measures:

  • The COVID-19 Vaccination Coverage Among Healthcare Personnel (HCP) measure to align with the updated Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network measure specifications;
  • The Cataracts: Improvement in Patient’s Visual Function Within 90 Days Following Cataract Surgery measure, to require use of one of three specific survey instruments to measure change in visual function pre- and post-operatively to further standardize data collection and reduce facility burden; and
  • The Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients measure, to align with updated clinical guidelines.

In addition, CMS is finalizing, with modification, the adoption of a new measure in these programs: the Risk-Standardized Patient-Reported Outcomes Following Elective Primary Total Hip and/or Total Knee Arthroplasty measure. According to the CMS fact sheet, this measure “will provide specific insight into the quality of care of a common procedure.” The measure will extend the voluntary reporting period to a total of three years prior to requiring mandatory reporting beginning with the 2028 reporting period for the 2031 payment determination.

Conversely, CMS is not finalizing its proposal to re-adopt the Hospital Outpatient Facility Volume Data on Selected Outpatient Surgical Procedures measure after consideration of commenter feedback. Commenters requested that CMS reconsider what data is collected for this measure to provide a complete picture of procedural volume that is meaningful to both patients and providers. The agency is also reassessing how the volume data is publicly displayed to ensure meaningfulness and relevance to providers, consumers, and other interested parties.

Further, the final rule adopts an additional measure in the Hospital OQR Program: the Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults electronic clinical quality measure (eCQM). The purpose of this measure is to promote patient safety. The measure extends the voluntary reporting period to a total of two years prior to requiring mandatory reporting beginning with the 2027 reporting period for the 2029 payment determination.

CMS is not finalizing its proposal to remove the Left Without Being Seen measure due to a recent increase (worsening) of LWBS rates in the agency’s routine monitoring and evaluation that warrants further investigation. Requests for comments were also solicited in the measure topic areas of patient safety and sepsis, behavioral health (including mental health and suicide risk), as well as telehealth in the hospital outpatient setting. A summary of the comments received is included in the final rule.

Rural Emergency Hospital Quality Reporting

The REHQR Program is a new quality reporting system for specially designated rural emergency hospitals (REHs) that must provide emergency department (ED) services and observation care and may also opt to provide additional outpatient services. These REHs are required by statute to submit quality measure data.

In the 2024 OPPS final rule, CMS is finalizing the adoption and codification of several standard quality program reporting policies, as well as the adoption of four initial measures for the REHQR Program. The four initial measures, consisting of three claims-based measures and one chart-abstracted measure, are:

  • Abdomen Computed Tomography – Use of Contrast Material;
  • Median Time from Emergency Department (ED) Arrival to ED Departure for Discharged ED Patients;
  • Facility Seven Day Risk Standardized Hospital Visit Rate after Outpatient Colonoscopy; and
  • Risk-Standardized Hospital Visits Within Seven Days After Hospital Outpatient Surgery.

In addition, CMS summarized comments received on the use of eCQMs, care coordination measures, and a tiered approach for quality measures and reporting requirements to incentivize REH reporting.

For a comprehensive review of the quality reporting rules for 2024, please consult the final rule, which can be found at the following website: 2023-24293.pdf (federalregister.gov)

With best wishes,

Chris Martin
Senior Vice President—BPO

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