Whether that ad worked or not or was accurate or not is for others to debate, but what cannot be debated is the fact that consumers demand quality in the products they purchase and the services they seek. The government recognized this some time ago when it began basing its Medicare payments on hospitals meeting certain quality metrics. The following details the latest requirements concerning quality measures for hospitals as found in the 2025 Outpatient Prospective Payment System (OPPS) proposed rule.
Outpatient Quality Reporting Program
The Outpatient Quality Reporting (OQR) Program is a pay-for-reporting quality program for hospital outpatient departments. Hospitals that fail to meet quality reporting requirements will receive a reduction of two percentage points in their annual payment.
The proposed rule would adopt the following new measures relative to the OQR Program:
- The Hospital Commitment to Health Equity (HCHE) measure beginning with the CY 2025 reporting period/CY 2027 payment determination;
- The Screening for Social Drivers of Health (SDOH) measure beginning with voluntary reporting in the CY 2025 reporting period, followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination; and
- The Screen Positive Rate for Social Drivers of Health (SDOH) measure, beginning with voluntary reporting in the CY 2025 reporting period followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination.
- The Patient Understanding of Key Information Related to Recovery After a Facility-Based Outpatient Procedure or Surgery, Patient Reported Outcome-Based Performance measure (Information Transfer PRO-PM). This measure would begin with voluntary reporting in the CY 2025 reporting period followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination. The measure is intended to provide specific insight into the communication of recovery information and enable hospital outpatient departments to improve patient understanding of such information.
CMS is also proposing to remove the following measures:
- The MRI Lumbar Spine for Low Back Pain measure beginning with the CY 2025 reporting period/CY 2027 payment determination, as recent studies have found that performance or improvement on the measure did not result in better patient outcomes; and
- The Cardiac Imaging for Preoperative Risk Assessment for Non-Cardiac, Low-Risk Surgery measure beginning with the CY 2025 reporting period/CY 2027 payment determination, because the wide range of cases per hospital outpatient department and lack of statistically distinguishable variation in performance indicates the measure does not provide sufficiently meaningful data to result in better patient outcomes.
Furthermore, the proposed rule would modify the Hospital OQR Program’s immediate measure removal policy, applicable when continued use of a measure raises patient safety concerns, to an immediate measure suspension policy. In the event of an immediate suspension, CMS would address the suspension and propose to retain, modify or remove the measure in the next feasible rulemaking cycle. CMS is proposing this change to align measure suspension policies across the REH, HOPD, and ASC quality reporting programs.
Lastly, CMS is proposing in this rule to require that Electronic Health Record (EHR) technology be certified to all eCQMs available to report in the Hospital OQR Program measure set to ensure that hospitals are able to accurately capture and report data for all eCQMs in the measure set. Pursuant to the proposed rule, the Median Time from Emergency Department (ED) Arrival to ED Departure for Discharged ED Patients measure – Psychiatric/Mental Health Patients strata be publicly reported on Care Compare.
Rural Emergency Hospital Quality Reporting Program
For the Rural Emergency Hospital Quality Reporting (REHQR) Program, CMS is proposing to adopt:
- The Hospital Commitment to Health Equity (HCHE) measure beginning with the CY 2025 reporting period/CY 2027 program determination;
- The Screening for Social Drivers of Health (SDOH) measure beginning with voluntary reporting in the CY 2025 reporting period followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 program determination; and
- The Screen Positive Rate for Social Drivers of Health (SDOH) measure beginning with voluntary reporting in the CY 2025 reporting period followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 program determination.
The proposed rule would extend the reporting period for the Risk-Standardized Hospital Visits Within 7 Days After Hospital Outpatient Surgery measure from one year to two years, beginning with the CY 2025 reporting period/CY 2027 program determination.
In addition, CMS is proposing to establish when, after conversion to REH status, REHs would be required to report data under the REHQR Program. Per the proposed rule, an REH would begin submitting data to the REHQR Program on the first day of the quarter following the date that a hospital has been designated as converted to an REH in accordance with the process outlined in section 1861(kkk) of the Act.
Overall Hospital Quality Star Rating
The Overall Hospital Quality Star Rating (OHQSR) provides a summary of certain existing hospital quality information on Medicare.gov based on publicly available quality measure results reported through CMS’ hospital quality measurement programs. The OHQSR assigns hospitals between one and five stars in a way that is simple and easy for patients to understand. Measures reported on the provider comparison tool on Medicare.gov (https://www.medicare.gov/care-compare/) that meet the criteria for inclusion in the OHQSR are organized into five conceptually coherent measure groups: Safety of Care, Mortality, Readmission, and Patient Experience (all of which include outcome measures), and Timely and Effective Care (which includes a selection of process measures).
The proposed rule notes that CMS is considering modifying the OHQSR methodology, specifically the Safety of Care measure group, in order to reinforce and emphasize patient safety. We’ll have to wait and see how that plays out. For the present, it’s clear that the “pay for performance” model isn’t going anywhere. Medicare seems set on tying reimbursement—at least in part—to what it deems as quality care.