Introduction
The Centers for Medicare & Medicaid Services (“CMS”) will withhold 1% of Medicare reimbursement payments as part of the Value-Based Purchasing Program (“VBP Program”) beginning today, October 1, 2012. This money will be used to fund incentive payments for participating hospitals in the VBP Program. Under the VBP Program, hospitals compete with one another based on selected quality and patient satisfaction performance measures for a share of the withheld money, estimated to be $850 million in federal fiscal year (“FFY”) 2013. Throughout FFY 2013, Medicare reimbursement for each hospital inpatient claim will be subject to a value-based incentive payment adjustment factor. High-performing hospitals could potentially receive more than a 1% return on the money withheld, while low-performing hospitals will see reimbursement reduced under the VBP Program. The amount initially withheld on each claim will rise by 0.25 percentage points per year until it is capped at 2% for FFY 2017.
FFY 2013 Hospital VBP Program
Hospital reimbursement in FFY 2013 will depend on performance scores for 13 total measures categorized into two domains: (1) Clinical Process of Care, which accounted for 70% of the Total Performance Score; and (2) Patient Experience of Care, which accounted for 30% of the Total Performance Score. The three-quarter performance period for these metrics ran from July 1, 2011 through March 31, 2012, and results were compared with a three-quarter baseline period, which ran from July 1, 2009 through March 31, 2010. Hospitals with higher Total Performance Scores will receive a higher value-based incentive payment adjustment per base DRG payment during FFY 2013 than those that receive lower Total Performance Scores. CMS notified each hospital of the estimated amount of its value-based incentive payment adjustments for FFY 2013 through its QualityNet account, and it is required by statute to provide each hospital the exact amount of its value-based incentive payment adjustment by November 1, 2012.
FFY 2014 Hospital VBP Measures
The FFY 2014 VBP Program will determine each hospital’s Total Performance Score based on its performance on 17 measures categorized into three domains: (1) Clinical Process of Care, which accounts for 45% of the Total Performance Score; (2) Patient Experience of Care, which accounts for 30% of the Total Performance Score; and (3) Mortality Outcome Measures, which accounts for 25% of the Total Performance Score. The performance period for both the Clinical Process of Care and Patient Experience of Care domains is underway. It runs from April 1, 2012 through December 31, 2012 and will be compared with a baseline period that occurred April 1, 2010 through December 31, 2010. The performance period for the Outcome Mortality domain was from July 1, 2011 through June 30, 2012 and has now concluded. Eligible hospitals will begin to receive incentive payment adjustments on October 1, 2013 based on the results of FFY 2014 Hospital VBP measures. Further information on the FFY 2014 Hospital VBP can be accessed at the following link: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/hospital-value-based-purchasing/index.html.
Practical Takeaways
In order to maximize reimbursement under the VBP Program, hospitals should consider the following:
- Review and analyze “Preview Reports” released by CMS on QualityNet;
- Frequently monitor VBP metrics and compare to benchmarks at set intervals (e.g., potentially through use of a monthly scorecard). Additionally, it is important to monitor all metrics measured through the Hospital Inpatient Quality Reporting (“IQR”) Program as these measures may be incorporated into the VBP Program in subsequent years;
- Request results from the Hospital Consumer Assessment of Healthcare Providers and Systems (“HCAHPS”) survey from hospital’s HCAHPS vendor and compare to benchmarks at set intervals; and
- Improve HCAHPS scores by working with all hospital personnel, including management, medical staff and hourly clinical and non-clinical employees, on the importance of patient satisfaction. Consider implementing specific programs to improve patient satisfaction, including hourly nursing rounds and increased patient education efforts from admission through the discharge process.
If you have any questions or would like additional information about this topic, please contact Jennifer A. Girod at 317.977.1414 or jgirod@hallrender.com, Brian C. Betner at 317.977.1466 or bbetner@hallrender.com or your regular Hall Render attorney.
