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2025 IPPS Final Rule: Quality Programs, Pt. 1

August 15, 2024

As you know from last week’s alert, the Centers for Medicare and Medicaid Services (CMS) has released its 2025 fiscal year (FY) Inpatient Prospective Payment System (IPPS) final rule, which goes into effect—in large part—on Oct 1 of this year. Part of that rule addresses multiple programs and requirements dedicated to quality measurement. Over the next two weeks, we will bring you quality-related highlights arising from the rule. This week’s offering will focus on the Hospital Inpatient Quality Reporting Program (QRP).

New Measures

The FY 2025 IPPS final rule contains several changes within the QRP. Included in these changes is the adoption of seven new measures:

  • Hospital Harm – Falls with Injury eCQM, with inclusion in the eCQM measure set beginning with the CY 2026 reporting period/FY 2028 payment determination.
  • Hospital Harm – Postoperative Respiratory Failure eCQM, with inclusion in the eCQM measure set beginning with the CY 2026 reporting period/FY 2028 payment determination.
  • Thirty-day Risk-Standardized Death Rate among Surgical Inpatients with Complications measure beginning with the July 1, 2023 – June 30, 2025 reporting period which impacts the FY 2027 payment determination.
  • Patient Safety Structural Measure beginning with the CY 2025 reporting period/FY 2027 payment determination, with modification.
  • Age Friendly Structural Measure beginning with the CY 2025 reporting period/FY 2027 payment determination.
  • Catheter-Associated Urinary Tract Infection Standardized Infection Ratio measure stratified for oncology locations beginning with the CY 2026 reporting period/FY 2028 payment determination.
  • Central Line-Associated Bloodstream Infection Standardized Infection Ratio measure stratified for oncology locations beginning with the CY 2026 reporting period/FY 2028 payment determination.

Revised Measures

CMS is modifying two current measures: 

  • Global Malnutrition Composite Score eCQM beginning with the CY 2026 reporting period/FY 2028 payment determination. This modification adds patients ages 18 to 64 to the current cohort of patients 65 years or older.
  • Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) Survey measure beginning with the CY 2025 reporting period/FY 2027 payment determination. The modifications refine the current HCAHPS Survey by adding three new survey sub-measures, removing one existing survey sub-measure, and revising one existing survey sub-measure. 

Deleted Measures

CMS is finalizing the removal of five measures: 

  • Four payment measures:
    • Hospital-level, Risk-Standardized Payment Associated with a 30-Day Episode of Care for Acute Myocardial Infarction (AMI Payment).  
    • Hospital-level, Risk-Standardized Payment Associated with a 30-Day Episode of Care for Heart Failure (HF Payment).
    • Hospital-level, Risk-Standardized Payment Associated with a 30-Day Episode of Care for Pneumonia (PN Payment).
    • Hospital-level, Risk-Standardized Payment Associated with a 30-Day Episode of Care for Elective Primary Total Hip Arthroplasty and/or Total Knee Arthroplasty (THA/TKA Payment).
      • CMS is finalizing these removals beginning with the FY 2026 payment determination, which is associated with a performance period of: July 1, 2021 – June 30, 2024, for the AMI Payment, HF Payment, and PN Payment measures; and April 1, 2021 – March 31, 2024, for the THA/TKA Payment measure.  
  • CMS PSI-04 Death Among Surgical Inpatients with Serious Treatable Complications measure beginning with the FY 2027 payment determination, associated with a July 1, 2023 – June 30, 2025, reporting period. CMS is finalizing the removal of this measure to replace it with the more broadly applicable Thirty-day Risk-Standardized Death Rate among Surgical Inpatients with Complications measure, as described above. 

Number of Measures

CMS is finalizing, with modifications, the proposal to increase the total number of eCQMs reported. Currently, the Hospital IQR Program requires reporting of six total eCQMs, three selected by CMS and three self-selected by hospitals. However, the number of reported measures required for future years will go up:

  • For the CY 2026 reporting period/FY 2028 payment determination, hospitals will be required to report on eight total eCQMs with five selected by CMS and three self-selected by hospitals.
  • For the CY 2027 reporting period/FY 2029 payment determination, hospitals will be required to report on nine total eCQMs with six selected by CMS and three self-selected by hospitals.
  • Beginning with the CY 2028 reporting period/FY 2030 payment determination, hospitals will be required to report on 11 total eCQMs, with eight selected by CMS and three self-selected by hospitals. 
  • In addition, CMS is finalizing the beginning of scoring for eCQM data validation, beginning with CY 2025 discharges that will impact the FY 2028 payment determination. 

Next week, we will continue to look at other reporting programs that will have potential implications for overall hospital reimbursement.

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