FY 2018 Hospital Inpatient Prospective Payment System (IPPS) Final Rule: CV-Specific Overview

News | Published: Monday, August 14, 2017

CMS has announced the FY 2018 IPPS Final Rule. MedAxiom has highlighted those issues that are cardiovascular in nature and included links to a fact sheet as well as the full Final Rule. Below is a summary table of the some of the most significant changes from 2017 to 2018. It is followed by key points impacting CV services.

Hospital Inpatient Prospective Payment System (IPPS) Overview

Logistics

The policy and payment changes will go into effect October 1, 2017
The CMS Fact Sheet on this rule can be found at: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-items/2017-08-02.html
The final 2018 IPPS rule can be found at: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/FY2018-IPPS-Final-Rule-Home-Page.html

Payment Changes

Factoring in various adjustments, CMS estimates a net average payment increase of 1.3% in FY 2018, plus a 0.7% increase in IPPS operating payments due to changes in the distribution of uncompensated care payments (see below)
In total, CMS projects that total Medicare spending on inpatient hospital services will increase ~$2.4 billion compared to last year
- On average, MS-DRG payment rates for major categories of cardiovascular services increased ranging from 0.8% to 3.6%
Uncompensated Care
- CMS is estimating to distribute $6.8 billion in uncompensated care payments in FY 2018, which represents an increase of ~$800 million from FY 2017
- CMS finalized its proposal to incorporate uncompensated care cost data from Worksheet S-10 of the Medicare cost report in determining how to distribute the uncompensated care funds

MS-DRG Changes (Cardiovascular Related)

TAVR and Left Atrial Appendage Closure (LAAC)
- Request was made to create a new MS-DRG when these two procedures were performed in the same operative episode
- CMS proposed and finalized the denial of this this request based on extremely low volume – these scenarios would continue to map to TAVR MS-DRGs
Percutaneous Mitral Valve Replacement Procedures
- Request received to map percutaneous valve replacement procedures to the same MS-DRGs (MS-DRGs 266-277) due to inconsistent mapping for percutaneous mitral valve replacement procedures.
- CMS proposed and finalized to map percutaneous mitral valve and tricuspid valve replacement procedures to MS-DRGs 266-267
Percutaneous Tricuspid Valve Repair
- Request received to reassign these procedures to MS-DRGs 228-229, which includes the FORMA Tricuspid Transcatheter Repair System
- CMS proposed and finalized the denial of this request based on clinical advisor input, and the cases would remain in MS-DRGs 216-221

Implantable Medical Device Credits

CMS policy states that if a hospital receives a credit for an implanted device equal to 50% or more of the cost of the device, CMS will reduce a hospital’s MS-DRG payment
This policy impacts 49 MS-DRGs (22 are cardiovascular related), and CMS is proposing no policy changes at this time

New Technology Add-On Payments (NTAP)

CMS provides incremental payment (in addition to the MS-DRG payment) for technologies and drugs that qualify for NTAP
Proposals for current NTAP technologies (cardiovascular related):
- CardioMEMS HF System – NTAP will be discontinued effective October 1, 2017
- Praxbind Idarucizumab (to reverse life-threatening bleeding events) – NTAP continues through FY 2018 (incremental payment cap of $1,750)
- Drug Coated Balloons – NTAP will be discontinued effective October 1, 2017
Proposals for New Applications
- Three applications evaluated – one is cardiovascular related
- INTUITY and Perceval Aortic Valves
  - Based on CMS’ evaluation and physician comments, CMS approved NTAP for both valves
  - The incremental payment (in addition to the MS-DRG payment) to hospitals is up to $6,110.23

Medicare Value Initiatives

Hospital Readmission Reduction Program
- CMS estimates 2,591 hospitals will incur a payment reduction, totaling $564 million (an increase of $27 million from 2017)
- For FY 2019, CMS will factor in dual-eligible patients in stratifying hospitals when developing hospital peer-groups. CMS contends this will ensure they are not disproportionately penalizing hospitals serving at-risk populations
Value Based Purchasing
- Percentage of payments impacted remains at 2.0%, and CMS estimates that $1.9 billion will be redistributed among hospitals
- CMS finalized the following, beginning in:
  - FY 2019 – Removed the current 8-indicator Patient Safety for Selected Indicators (PSI 90) measure from the Safety domain
  - FY 2021 – Revised the Efficiency and Cost Reduction domain weighting to reflect the implementation of condition-specific payment measures in the Hospital VBP Program
  - FY 2022 – Adopted the Hospital-Level, Risk-Standardized Payment Associated with a 30-day Episode of Care for Pneumonia measure for the Efficiency and Cost Reduction domain
  - FY 2023 – Adopted the 10-indicator modified Patient Safety and Adverse Events Composite PSI 90 measure

Inpatient Quality Reporting (IQR) Program

CMS finalized voluntary reporting of one new measure, the Hybrid Hospital-Wide Readmission Measure with Claims and Electronic Health Record Data, for the CY 2018 reporting period – this measure does not impact payment adjustments
CMS is changing the reporting requirements for electronic clinical quality measures (eCQMs)
- Hospitals may report on 4 (instead of 8 currently, and 6 that were proposed) of available eCQMs
- Hospitals may submit one (instead of 2 as proposed) self-selected quarters of data, instead of one full calendar year
CMS will allow hospitals to report with 2014 CEHRT or 2015 CEHRT or a combination of both to report FY 2018 eCQMs
CMS finalized that EHR technology certified to the 2014 or 2015 Edition must be certified to all 15 eCQMs available to report in the Hospital IQR Program
CMS finalized that an EHR certified for eCQMs under the 2014 or 2015 Edition certification criteria would not need to be recertified each time it is updated to a more recent version of the eCQM electronic specifications.

Changes to the Medicare and Medicaid EHR Incentive Programs

CMS finalized modifying EHR reporting periods in 2018 for new and returning participants attesting to CMS or State Medicaid agency from a full year to a minimum of any continuous 90-day period within CY 2018
CMS finalized adding a new exception for eligible professional (EP) who demonstrate (via application) that compliance under EHR program is not possible because the certified EHR technology has been decertified under ONC’s Health IT Certification Program
CMS finalized that no payment adjustment may be made in the case of an EP who furnishes substantially of their professional services in the ASC setting, defined as an EP who provides 75% or more of professional services in the ASC setting in the calendar year that is two years before the payment adjustment

If you are not currently a MedAxiom or Cardiology Advocacy Alliance (CAA) member, this would be an excellent time to join. With all the regulatory, political and industry changes taking place, staying informed is essential for success. Members receive ongoing, detailed information and analysis of proposed and final rulings that significantly impact CV health care providers, including detailed DRG rate change spreadsheets. To learn more about MedAxiom membership, go to www.medaxiom.com; for more on CAA, visit www.cardiologycaa.com. You may also contact me directly with questions or comments at [email protected].

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FY 2018 Hospital Inpatient Prospective Payment System (IPPS) Final Rule: CV-Specific Overview

Hospital Inpatient Prospective Payment System (IPPS) Overview

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