CMS expects few hospitals to participate in readmissions experiment

The CMS expects few providers to volunteer for an experiment to help track unplanned readmissions and their causes, even though the pilot is a precursor for a mandatory change in how hospitals are penalized.

In the fiscal 2018 inpatient pay rule released last month, the agency finalized plans for a pilot to test a new hybrid hospitalwide readmissions measure. The new approach estimates unplanned returns to the hospital within 30 days of discharge using clinical data from patients' electronic health records as well as Medicare claims data.

The program would be voluntary in 2018 so the CMS can test the measure's accuracy. The agency hopes to make the metric mandatory for all hospitals receiving Medicare reimbursement in 2021. That will affect hospitals' penalties for readmissions. Hospitals who participate in the pilot will not have their Medicare payments altered during the voluntary phase.

In a notice posted Thursday, the CMS estimates no more than 100 of the 3,000 hospitals now paid under the inpatient fee schedule will volunteer. The agency didn't provide an explanation for the lack of interest.

A small pilot with few volunteers could affect the experiment's accuracy, according to some hospital industry stakeholders.

"We are concerned about whether the hospitals that participate will represent a sufficiently diverse set of hospitals to enable CMS to make a decision about whether to make this policy mandatory in the future," said Ivy Baer, regulatory counsel at the Association of American Medical Colleges.

There is also some concern over whether the CMS can find out if the new approach works as intended without more participation in the pilot.

"A low return rate makes the results more volatile in terms of drawing conclusions," said Joel Sauer, a vice president at MedAxiom, a medical practice consulting firm. "Trying to draw conclusions for the entire 3,000 population on such a small sample is quite problematic. "

Currently, Medicare only uses claims data to evaluate hospitals' unplanned readmissions. Hospitals face $564 million in readmission penalties next year. That's up $27 million from this fiscal year.

Dr. Lee Sacks, Advocate Health Care's executive vice president and chief medical officer, said he believes the new readmission metric will lead to better risk adjustment and ultimately improve care.

However, the agency's timeline may be too tight for hospitals to prepare to collect and validate these data next year, Sacks said. Providers would need to work with electronic health record vendors to get the specific information the new approach requires, which would take some time.

"Going live in January is unrealistic," Sacks said.

Hospitals also may be overwhelmed already with the quality measures they have to report under Medicare.

"Since hospitals are struggling to report the required (metrics), it's unlikely that they will voluntarily report any additional ones," said Aisha Pittman, senior director of quality payment policy at the consulting firm Premier.

The CMS should find ways to entice hospitals to use the new voluntary reporting measures and generate higher participation, she said.

Even if hospitals were ready and interested in voluntarily reporting under the measure there is concern that the CMS does not have a the IT infrastructure to collect these data, according to Robert Hemker, CEO of Palomar Health, a three-hospital system based in Escondido, Calif.

"CMS continues to have challenges with all of its portals," Hemker said in a comment letter to the agency. "Before proceeding further, we ask CMS to make the infrastructure investments needed to ensure timely upload and receipt of data."