“Take me home, country roads, to the place I belong.” So begins the iconic chorus to one of America’s favorite tunes dedicated to rural settings and down-home living. While most of our citizens live in urbanized areas, with ready access to an array of services and conveniences, those who dwell in the hills and hollers of the nation’s backcountry are no less in need of certain essentials—such as quality medical and emergency care.
In its 2024 Outpatient Prospective Payment System (OPPS) Proposed Rule, the Centers for Medicare and Medicaid Services (CMS) addresses several issues that would apply to America’s rural hospitals in the coming year, if finalized. This article will act to summarize some of the highlights of the rule’s proposals pertaining to such hospitals.
Indian Health Service (IHS) Facilities and Tribal Facilities
By way of reminder, in the 2023 OPPS final rule, CMS created regulations establishing the Rural Emergency Hospital (REH) provider type. A hospital is eligible to convert to an REH if it was a critical access hospital or rural hospital, with no more than 50 beds, participating in Medicare as of the date of enactment of the Consolidated Appropriations Act (CAA), 2021. Eligible hospitals that convert to an REH receive an enhanced rate for REH services and a fixed monthly facility payment.
While some tribal and IHS hospitals have expressed interest in converting to an REH, they have expressed significant reservations about transitioning from their existing payment methodology under the All-Inclusive-Rate (AIR), published annually by the IHS in the Federal Register, to the REH payment methodology. With that said, CMS is proposing the following:
- IHS and tribal facilities that convert to REHs be paid for hospital outpatient services under the same AIR that would otherwise apply if these services were performed by an IHS or tribal hospital that is not an REH. The existing beneficiary coinsurance policies applicable to such services under the AIR would remain the same.
- IHS and tribal facilities that convert to REHs would receive the REH monthly facility payment consistent with how this payment is applied to REHs that are not tribally or IHS operated. CMS expects this approach, if finalized, would bring further stability to IHS facilities that decide to convert to REHs and better promote access to tribal and IHS hospitals.
Hospital Outpatient/REH Quality Reporting Programs
CMS is proposing changes to the Hospital Outpatient Quality Reporting (OQR) and Rural Emergency Hospital Quality Reporting (REHQR) Programs to further meaningful measurement and reporting for quality of care in the outpatient setting.
Hospital Outpatient Quality Reporting (OQR)
The Hospital OQR Program is a pay-for-reporting quality program for the hospital outpatient department setting that requires hospitals to meet quality reporting requirements. Hospitals that fail to meet these requirements will face a reduction of 2.0 percentage points in their annual payment update.
In the proposed rule, CMS is modifying three measures within the program:
- 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 survey instrument 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 proposing the adoption of two measures in these programs:
- The Risk-Standardized Patient-Reported Outcomes Following Elective Primary Total Hip and/or Total Knee Arthroplasty measure to provide specific insight into the quality of care of a common procedure; and
- The Hospital Outpatient/ASC Facility Volume Data on Selected Outpatient Surgical Procedures measures with modifications from the previously adopted version of the measures that were removed from the programs to increase measure granularity.
Further, the rule is proposing the adoption of 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). This new measure is designed to promote patient safety. The proposed rule also removes the Left Without Being Seen measure, as it does not provide actionable information in sufficient detail to improve quality and, subsequently, patient outcomes.
Rural Emergency Hospital Quality Reporting (REHQR) Program
To reinforce what we stated above, an REH is a facility that, as of December 27, 2020, was a Critical Access Hospital (CAH) or a subsection (d) hospital with not more than 50 beds located in a county (or equivalent unit of local government) that is in a rural area [defined at section 1886(d)(2)(D) of the Act] or was a subsection (d) hospital with not more than 50 beds that was treated as being in a rural area pursuant to the Act. An REH must submit quality measure data to the Secretary, and the Secretary is to establish procedures to make the data available to the public on a CMS website.
In the proposed rule, CMS adopts several standard quality program reporting policies, as well as four initial measures for the REHQR Program. The four proposed initial measures, consisting of three claims-based measures and one chart-abstracted measure, are: (1) Abdomen CT: Use of Contrast Material; (2) Median Time from Emergency Department (ED) Arrival to ED Departure for Discharged ED Patients; (3) Facility Seven Day Risk Standardized Hospital Visit Rate after Outpatient Colonoscopy; and (4) Risk-Standardized Hospital Visits Within Seven Days After Hospital Outpatient Surgery. For more information about rural hospital and other provisions that are found in the proposed rule, go to CY 2024 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule (CMS 1786-P) | CMS.
Catch up on our previous alert regarding the 2024 OPPS Proposed Rule here.
With best wishes,
Senior Vice President—BPO