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Federal Register / Vol. 86, No. 129 / Friday, July 9, 2021 / Proposed Rules
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Estimates. In the CY 2016 ESRD PPS
final rule 80 FR 69069, we stated that it was reasonable to assume that Medical Records and Health Information Technicians, who are responsible for organizing and managing health information data, are the individuals tasked with submitting measure data to CROWNWeb now EQRS and NHSN, as well as compiling and submitting patient records for purpose of the data validation studies, rather than a Registered Nurse, whose duties are centered on providing and coordinating care for patients. We stated that the median hourly wage of a Medical Records and Health Information Technician is $21.20 per hour.304 We also stated that fringe benefit and overhead are calculated at 100 percent. Therefore, using these assumptions, we estimated an hourly labor cost of $42.40 as the basis of the wage estimates for all collections of information calculations in the ESRD
QIP. We adjusted these employee hourly wage estimates by a factor of 100
percent to reflect current HHS
department-wide guidance on estimating the cost of fringe benefits and overhead. We stated that these are necessarily rough adjustments, both because fringe benefits and overhead costs vary significantly from employer to employer and because methods of estimating these costs vary widely from study to study. Nonetheless, we stated that there is no practical alternative and we believe that these are reasonable estimation methods.
We used this updated wage estimate, along with updated facility and patient counts to re-estimate the total information collection burden in the ESRD QIP for PY 2024 that we discussed in the CY 2021 ESRD QIP
final rule 85 FR 71473 through 71474
and to estimate the total information collection burden in the ESRD QIP for PY 2025. We provide the re-estimated information collection burden associated with the PY 2024 ESRD QIP
and the newly estimated information collection burden associated with the PY 2025 ESRD QIP in section VII.C.3 of this proposed rule.
2. Estimated Burden Associated With the Data Validation Requirements for PY
2024 and PY 2025 OMB Control Numbers 09381289 and 09381340
In the CY 2020 ESRD PPS final rule, we finalized a policy to adopt the CROWNWeb data validation methodology that we previously adopted for the PY 2016 ESRD QIP as 304 https www.bls.gov/oes/current/
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the methodology we would use to validate CROWNWeb data for all payment years, beginning with PY 2021
83 FR 57001 through 57002. Although, as noted in section IV.B.2 of this proposed rule, we are now using EQRS
to report data that was previously reported in CROWNWeb, the data validation methodology remains the same. Under this methodology, 300
facilities are selected each year to submit 10 records to CMS, and we reimburse these facilities for the costs associated with copying and mailing the requested records. The burden associated with these validation requirements is the time and effort necessary to submit the requested records to a CMS contractor. In this proposed rule, we are updating these estimates using a newly available wage estimate of a Medical Records and Health Information Technician. In the CY 2020 ESRD PPS final rule, we estimated that it would take each facility approximately 2.5 hours to comply with this requirement. If 300
facilities are asked to submit records, we estimated that the total combined annual burden for these facilities would be 750 hours 300 facilities x 2.5 hours.
Since we anticipate that Medical Records and Health Information Technicians or similar administrative staff would submit these data, we estimate that the aggregate cost of the EQRS data validation each year would be approximately $31,800 750 hours
$42.40, or an annual total of approximately $106.00 $31,800/300
facilities per facility in the sample. The burden cost increase associated with these requirements will be revised in information collection request OMB
control number 09381289.
In the CY 2021 ESRD PPS final rule, we finalized our policy to reduce the number of records that a facility selected to participate in the NHSN data validation must submit to a CMS
contractor, beginning with PY 2023 85
FR 71471 through 71472. Under this finalized policy, a facility is required to submit records for 20 patients across any two quarters of the year, instead of 20 records for each of the first two quarters of the year. The burden associated with this policy is the time and effort necessary to submit the requested records to a CMS contractor.
Applying our policy to reduce the number of records required from each facility participating in the NHSN
validation, we estimated that it would take each facility approximately 5 hours to comply with this requirement. If 300
facilities are asked to submit records each year, we estimated that the total
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combined annual burden hours for these facilities per year would be 1,500 hours 300 facilities 5 hours. Since we anticipate that Medical Records and Health Information Technicians or similar staff would submit these data, using the newly available wage estimate of a Medical Records and Health Information Technician, we estimate that the aggregate cost of the NHSN data validation each year would be approximately $63,600 1,500 hours
$42.40, or a total of approximately $212
$63,600/300 facilities per facility in the sample. While the burden hours estimate will not change, the burden cost updates associated with these requirements will be revised in the information collection request OMB
control number 09381340.
3. EQRS Reporting Requirements for PY
2024 and PY 2025 OMB Control Number 09381289
To determine the burden associated with the EQRS reporting requirements previously known as the CROWNWeb reporting requirements, we look at the total number of patients nationally, the number of data elements per patientyear that the facility would be required to submit to EQRS for each measure, the amount of time required for data entry, the estimated wage plus benefits applicable to the individuals within facilities who are most likely to be entering data into EQRS, and the number of facilities submitting data to EQRS. In the CY 2021 ESRD PPS final rule, we estimated that the burden associated with CROWNWeb now EQRS reporting requirements for the PY 2024 ESRD QIP was approximately $208 million 85 FR 71400.
As discussed in section IV.C and section IV.D of this proposed rule, we are proposing measure suppressions that would apply for PY 2022 and updates to the scoring methodology and payment reductions for the PY 2022
ESRD QIP. We also announce an extension of EQRS reporting requirements for facilities due to systems issues. However, we believe that none of the policies proposed in this proposed rule would affect our estimates of the annual burden associated with the Programs information collection requirements, as facilities are still expected to continue to collect measure data during this time period. We are not proposing any changes that would affect the burden associated with EQRS reporting requirements for PY 2024 or PY 2025.
However, we have re-calculated the burden estimate for PY 2024 using updated estimates of the total number of dialysis facilities, the total number of
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