Federal Register - August 4, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations
such facilities should continue to transmit data using their existing infrastructure and timelines.
Because we believe that the costs are now increased and the benefits are now reduced, we believe that the costs and burdens associated with this chartabstracted measure outweigh the benefit of its continued use in the IPFQR
Program.
Therefore, we proposed to remove the Timely Transmission of Transition Record Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care measure from the IPFQR
Program beginning with the FY 2024
payment determination. We welcomed public comments on our proposal to remove the Timely Transmission of Transition Record Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care measure from the IPFQR Program.
We received the following comments on our proposal.
Comment: Many commenters supported the removal of the Timely Transmission of Transition Record Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care measure. One commenter recommended immediate removal to further reduce burden. Another commenter expressed that this measure was not developed for IPFs and has been difficult to report because the specifications are not appropriate for the setting. Another commenter further noted that the measure is no longer NQF
endorsed.
Response: We thank the commenters for their support. We considered removing the measure sooner, but because data are currently being collected to report during CY 2022 to inform the FY 2023 payment determination, we decided to propose removing the measure following that payment determination, therefore we proposed removal for the FY 2024
payment determination. The commenter is correct that the measure is no longer NQF endorsed and is not specified for the IPF setting; however we continue to believe that this measure is appropriate for the setting. We reiterate that removal of the measure is because we believe that the costs of the measure outweigh its continued benefits in the IPFQR
Program.
Comment: Some commenters observed that the updated CoPs will not apply to many IPFs, especially freestanding IPFs that are not part of larger healthcare facilities, because IPFs were excluded from Meaningful Use incentives and therefore often do not have electronic data systems capable of
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meeting the standards in the updated CoPs.
Response: We acknowledge that there are a large number of IPFs that do not possess EHR systems with the technical capacity to generate information for electronic patient event notifications of a patients admission, discharge, or transfer to another health care facility or to another community provider, or combination of patient events at the time of a patients discharge or transfer.
However, for those IPFs that can meet these requirements, we believe that retaining the Timely Transmission of Transition Record Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care measure could be burdensome depending on how facilities implement new requirements.
Therefore, while for some IPFs the benefits may outweigh the costs, overall, for the IPFQR Program we believe the costs now outweigh the benefits. We reiterate that for IPFs that do not possess EHR systems with the capacity to generate information for patient event notifications as defined in the CoP
regulations set forth at 42 CFR
482.24d, such facilities should continue to transmit data using their existing infrastructure and timelines.
Comment: A few commenters recommended that CMS retain the Timely Transmission of Transition Record Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care measure. Some of these commenters believe that the measures benefits are more significant than the burden. One commenter recommended that CMS seek consumer input on benefits prior to proposing measures for removal.
Response: We reiterate that we do not believe that the benefits of transmitting the transition record within 24 hours of discharge are reduced, or are lower than the costs of reporting; we believe that given the updates to the CoPs which overlap with this measure the benefits of retaining the Timely Transmission of Transition Record Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care measure are no longer sufficient to justify retention. We used the notice and comment rulemaking process to solicit input on measure benefits from all stakeholders, including consumers.
After consideration of the public comments, we are finalizing our proposal to remove the Timely Transmission of Transition Record Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care measure beginning with the FY
2024 payment determination.
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d. Removal of the Follow-Up After Hospitalization for Mental Illness FUH, NQF 0576 Beginning With FY 2024
Payment Determination In the FY 2022 IPF PPS proposed rule we stated that if we finalize adoption of the Follow-Up After Psychiatric Hospitalization measure described in section IV.E.3, we believed that our current measure removal Factor 3 would apply to the existing Follow-Up After Hospitalization for Mental Illness FUH, NQF 0576 measure 86 FR 19510.
Measure removal Factor 3 applies when a measure can be replaced by a more broadly applicable measure across settings or populations or a measure that is more proximal in time to desired patient outcomes for the particular topics. We adopted removal factor 3 in the FY 2017 IPPS/LTCH PPS final rule 82 FR 38463 through 38465. The FAPH measure expands the patient population from patients with mental illness to also include patients with primary SUD diagnoses while addressing the same important aspect of care transitions. Because this FAPH
measure uses the same methodology to address the same element of care for a broader patient population than the FUH measure, we believe that it is more broadly applicable across populations.
Therefore, we proposed to remove the FUH measure under measure removal Factor 3 only if we finalized our proposal to adopt of the FAPH measure.
We noted that if we did not adopt the FAPH measure, we would retain the FUH measure because we believe this measure addresses an important clinical topic. We welcomed public comments on our proposal to remove FUH if we were to adopt FAPH.
We received the following comments on our proposal.
Comment: Many commenters supported removal of this measure.
Some commenters specifically noted that FAPH is more broadly applicable and therefore preferable.
Response: We thank these commenters for their support.
Comment: One commenter does not support either the FUH measure or the FAPH measure due to the belief that measures of follow-up after hospitalization are not appropriate for the IPFQR Program and recommended removing the FUH measure but not adopting the FAPH measure.
Response: For the reasons set forth in the FY 2014 IPPS/LTCH PPS final rule 78 FR 50894 through 50895 and the FY
2022 IPF PPS proposed rule in our proposal to adopt the FAPH measure 86
FR 19504 through 19507, we believe that a measure of follow-after
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