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9/17/2018
1
The In’s and Out’s of the CMS Readmission Program
Kristi Sidel MHA, BSN, RN Director of Quality Initiatives
Objectives
• General overview of the Hospital Readmission Reductions Program
• Description of measures
• What Avera is doing to improve our readmission rates
Todays Inspiration
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Meaningful Measures Initiative
CMS’s new initiative, Meaningful Measures, is a component of Patients Over Paperwork initiative
– Launched in 2017 to identify high priority areas for quality measurement and improvement
For more information: https://www.cms.gov/Medicare/Quality‐Initiatives‐Patient‐Assessment‐Instruments/QualityInitiativesGenInfo/CMS‐Quality‐Strategy.html
Meaningful Measures
Source: CMS FY 2019 IPPS Final Rule Acute Care Hospital Quality Reporting Programs Overview 9.12.18
Hospital Value‐Based Purchasing Programs
• Hospital quality initiatives are aimed at improving the quality, efficiency and overall value of healthcare
• Inpatient hospital programs:
– Hospital Inpatient Quality Program (IQR)
• Hospital Value‐Based Purchasing Program (HVBP)
• Hospital Readmissions Reduction Program (HRRP)
• Hospital‐Acquired Condition Reduction Program (HAC)
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What is the Hospital Readmissions Reduction Program (HRRP)??
Of the three P4P (pay for performance) program, the readmission penalties are the most significant for inpatient payments.
• Hospitals can lose up to 3% of reimbursement depending on their readmission performance
What is the Hospital Readmissions Reduction Program (HRRP)??
Background
• Mandated by the Affordable Care Act – requires CMS to reduce payments to Inpatient Prospective Payment System (IPPS) hospitals with excess readmissions
• Program supports CMS’s national goal of improving healthcare by linking payment and the quality of hospital care
• Strong financial incentive to: – Improve communication
– Improve care coordination efforts
– Better engage patients and caregivers in post‐discharge planning
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Readmission National Penalties
The HRRP hospitals do not include:
• Long‐term care hospitals
• Critical access hospitals
• Rehabilitation hospitals and units
• Psychiatric hospitals and units
• Children’s hospitals
• PPS‐exempt cancer hospitals
What is a 30d Readmission?
A patient who is admitted for any reason to the same or another acute‐care hospital within 30 days of discharge.
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Factors Affecting Readmissions:
• Patient’s diagnosis
• Severity of illness
• Patient’s behavior
– Adherence to discharge instructions
– Availability and quality of post‐discharge care
What hospitalizations are not readmissions?
The following types of admissions are not considered readmissions in the measure:
– Planned readmissions (chemotherapy or pre‐planned surgery)
– Same‐day readmissions to the same hospital for the same condition
– Observation stays and Emergency Department visits
– Admissions to facilities other than short‐term acute care hospitals (such as rehab, neonates, psych, hospice, LTC, and skilled nursing facilities) do not meet definition
Continuing Controversy
• Observation vs. Inpatient
• All Readmissions vs. avoidable readmissions
• Lack of risk adjustment for key socioeconomic factors (usually outside the hospitals control)
• The inclusion of readmissions unrelated to the initial admission
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30 day Readmission Measures
Inclusion Criteria
1. Having a principal discharge diagnosis of AMI, COPD, HF, pneumonia for each respective measure
2. Enrolled in Medicare FFS or are VA beneficiaries
3. Aged 65 and over
4. Discharged alive from a non‐federal short‐term acute care hospital or VA hospital
5. Not transferred to another acute care facility
Procedure Specific Inclusion Criteria
1. Having a qualifying isolated CABG surgery or elective primary THA/TKA procedure during the index admission
2. Enrolled in Medicare Fee‐For‐Service (FFS) Part A and Part B
3. Aged 65 or over
4. Discharged alive from a non‐federal short‐term acute care hospital
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Exclusion Criteria
1. Without at least 30 days of post‐discharge enrollment in FFS Medicare
2. Discharged against medical advice (AMA)
3. Same‐day discharges
What is a planned readmission?
Transfer Scenarios
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Swingbed Stays
• A swingbed admission itself is not eligible to be an index admission (or a readmission), as only short‐term acute care hospitalizations are considered for index admissions or readmissions
How “were” Readmissions Measured
• Goal < 1.000
• Calculate Excess Readmission Ratio
Facility Observed Value
Facility Expected Value
• Excess Readmission Ratio > 1.000 = PENALTY
How “were” Readmissions Measured
Non‐Stratified HRRP Payment Methodology
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How “are” Readmissions Measured Now
CMS FY18 IPPS Final Rule• Congress Mandates HRRP Adjust for Dual Eligibility – Hospitals will be sorted into five peer hospital cohorts – Cohorts defined by quintile of dual eligible inpatient stays as a proportion of total Medicare inpatient stays during HRRP performance period
– Within cohorts, hospitals’ excess readmission ratio (ERR) for each condition compared to cohort’s median ERR for that condition.
– Hospitals with ERRs exceeding group’s median will earn penalty
How “are” Readmissions Measured Now
Stratified Methodology
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Risk Adjustment
“Once again the severity of illness based on comorbid conditions influences the risk adjustment. Sicker patients are expected to have higher readmission rates, so hospitals with a patient population reflecting higher severity will have their readmission rate adjusted downward and therefore are less likely to be penalized.”
Pinson & Tang, 2016 CDI Pocket Guide
Risk Adjustment – All Diagnoses
There are tons of them! • Metastatic cancer or leukemia • Diabetes Mellitus • Protein‐calorie malnutrition • Disorders of fluid, electrolyte, or
acid‐base • Dementia• Iron deficiency • Liver or biliary disease • Depression • Drug/alcohol abuse, dependence
or psychosis • Cardio‐respiratory failure or
shock
• Septicemia/shock• Hemiplegia, paraplegia, paralysis,
functional disability • Respiratory dependence/failure• CHF• Angina • Asthma• Stroke• COPD• Pneumonia• ESRD or dialysis • Decubitus ulcer or chronic skin
ulcer
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Noncompliance & Readmissions
• 89.7% ‐ Reason for readmission listed as “other”
• 10.3% ‐ Reason for readmission listed as “dietary or medication noncompliance –related”
– 47% of adults have limited health literacy skills
– 44% of adults are functionally health illiterate
‐ The Advisory Board Company, 2016
Noncompliance
“CDI specialists can assist facilities by identifying when noncompliance plays a role in the readmission. By securing the necessary documentation to allow coders to report [noncompliance], hospitals can use this documentation and coded date to help prevent or appeal denials… If [it] is reported on the UB‐04, [it allows] the payer to have the knowledge that patient noncompliance may have contributed to the readmission.”
ACDIS
Social Risk Factors
• CMS is considering options to address equity and disparities in its value‐based purchasing programs
• A recent report from the Assistant Secretary for Planning and Evaluation identified dual eligibility as the most powerful predictor of poor healthcare outcomes among social risk factors tested
• The goal is to improve health disparities by increasing transparency and comparing those disparities across hospitals
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Are you feeling like this yet?
Avera’s Game Plan
Serving 86 counties in a five‐state region
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Footprint
Readmissions – Why Now?
• Variety of initiatives across Avera “throwing the kitchen sink at readmissions”
• Historical performance
• Current performance – trending up
• New Final Rule that increases penalty potential
The Kitchen Sink
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System wide Approach Medical Staff
Nursing
Case Management
Quality
Finance
IT
C‐Suite
HIM/CDI
Patient Flow
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Readmission Lunch and Learn Concept
Endorsement was received by the Chief Medical Officers to deep dive into readmissions across the system. Next steps included:
– Identification of key stakeholders across the system to form a readmissions steering committee
• Time limited steering committee
• Role is to guide content for lunch and learns
– Monthly lunch and learn sessions to share best practices and collaboration across continuums
– In Person readmissions summit to wrap the series up
Lunch and Learn Topics
Intro to HRRPCare
TransitionsMed Rec
Discharge Planning
Coordinated Care / Long Term Care
ACO 101 Home Health Emergency Department
Performance Improvement
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Strategies to improve
• Promote a culture of transparency and integrity • Know where your hospital stands on each selected measure
• Run, use and share reports – look at your data – Severity of illness– Risk of mortality– Present on admission – PSI – Length of stay – Readmissions– Cost per patient
In Conclusion
The numbers don’t lie – patients you are sicker, with more chronic conditions, have an increased risk of readmissions. However…
– During chart reviews, you are already identifying ways to improve your patients severity of illness or risk of mortality (SOI & ROM) scores
–Work with your Quality team to identify all diagnoses that , if established in the record, can best benefit a hospital’s risk adjustment
Data isn’t just Numbers