Thursday, April 11, 2024

Brief Blog: CMS Issues Inpatient Draft Rule FY2025; SEP-1 noted

The summer rulemaking season kicked off this week with release of the Inpatient Proposed Rule for FY2025 (October 1).  It's logged as CMS-1808-P [proposed].    

This will be followed by Physician and Hospital Outpatient rules circa July 1, for CY2025 (January 1).

Find the detailed fact sheet here.

The press release (which is allowed more spin) is here.

As always, CMS has released a typescript "inspection copy," 1902pp, opened a 60 day comment period, and will publish the typeset Fed Reg rule on May 2.   Here.


Improved "New Tech Add On Payment" Evaluations

The clarity with which CMS handles the new tech add on payment applications (each year 10-20 of these) continues to improve.   CMS offers key questions, presented in rows in a tabular format where the  applicant provides his/her answer and justification.   For example, "Is the technology "new"?"   Answer: Yes.   Reason:  (Three sentences explaining why it is new.)    Some of this clarity probably would help in other areas like dossiers to MolDx or other MACs and payers or ADLT applications/

CMS provides these summary tables in the Fed Reg while directing the reader to online sources for back up detail.  Snippet here:

click to enlarge (IPPS pdf p 285)


For those who missed it, the Medicare Advantage final rule came out April 4, 2024, and can be found here.

Inpatient Rule - SEP 1

Last year, CMS determined a timetable to elevate SEP-1 from a reportable measure to a financial impactful value based purchasing measure.   This is shown on page 729, Table V-L-02 (2026-2030).  Later on page 852, CMS cites to a PCAST report, "Transformational Effort on Patient Safety," September 2023, which had four goals, e.g. research and deployment for safe care measures.  CMS then states that specific condition or specific procedure measures, like SEP-1, "are not suffficient to measure and incentivize investment in a resilient safety culuture or [investment in] the infrastructure necessary for sustainable high performance within the broad and complex doamin of patient safety."  And, "There is strong alignment among experts to shift to a more holistic, proactive, systems-based approach to safety."  But existing measues focus on improving "patient safety for a specific condition..[not] the overall culture in which care is provided."  This leads up (p 854) to proposing a Patient Safety Structural Measure with 5 complementary domains which will be "foundational."  There are no changes at this time in the policy forecast of chart-based SEP-1 measurement out to 2030. 

There are some concerns and changes regarding accuracy of chart-abstraced measures (p 986).