Hospitals think it's too soon for CMS to require them to report COVID-19 vaccination information about their workforce, according to comments on the inpatient prospective payment system proposed rule.
CMS wants hospitals to report the percentage of their healthcare personnel immunized against COVID-19, including independent practitioners affiliated but not directly employed by inpatient facilities. But hospitals said it's too early to require the jabs, given that coronavirus vaccines have only been available for six months and that there are outstanding questions about how long people will remain protected after vaccination.
"A premature mandate to report this measure would lead to unpredictable shifts in reporting requirements that would prove disruptive to hospitals, and result in data that are unhelpful to policymakers, the public and health care providers," the American Hospital Association said in a comment letter.
The AHA and other provider groups recommended that CMS delay the reporting requirements or make the measure voluntary for the first year. CMS intends to require hospitals to start reporting vaccination rates for their clinical staff beginning Oct. 1.
Hospitals are also concerned that the CMS' proposed COVID-19 measure hasn't been endorsed by the National Quality Forum, which is required for other CMS quality measures. Going through the NQF review and endorsement process should help ensure that the measure is valid.
Likewise, hospitals are worried that differences in hospitals' vaccination policies could lead to uneven vaccination rates among hospitals, which might cause the public to panic.
"Some hospitals have implemented a vaccination requirement policy for all employees, while others have limited requiring vaccination to those with certain job functions, and still others are awaiting full approval of the vaccines by the Food and Drug Administration before making such decisions," America's Essential Hospitals said in a comment letter. "Given this potential variation in hospital policies, we urge CMS to refrain from publicly reporting this data."
CMS' proposal to add a new maternal morbidity measure to the Inpatient Quality Reporting program also got providers' attention. Under the plan, hospitals would have to report whether they participate in a state or national perinatal quality improvement collaborative and whether they implement the patient safety practices or bundles included in those initiatives.
Although hospital groups generally supported CMS' efforts to monitor and improve maternal mortality, they questioned whether it made sense to make it permanent. It doesn't measure outcomes, so it might not have much long-term value.
"Hospitals cannot use this measure for benchmarking purposes because all it tells them is whether their peers are participating in improvement projects. The measure also does not provide actual performance data on maternal morbidity to patients and families trying to make a better-informed decision about where to receive their maternal care," AHA wrote.
But hospitals urged CMS to adopt the measure, anyway, viewing it as a first step towards improving maternal mortality measures.
"Given the importance of addressing maternal morbidity, it is vital for such work to begin," AHA wrote.
AEH also encouraged CMS to evaluate racial disparities that could affect maternal health outcomes, including factors like language access, structural racism, mental health and implicit bias.
"CMS should continue to examine ways to appropriately risk adjust quality measures across its programs to account for factors outside the control of hospitals that impact health outcomes. CMS should not include in the IQR Program outcome measures sensitive to sociodemographic factors—e.g., readmissions, mortality, episode payments—until the measures have been risk-adjusted," the group wrote.
Hospitals also supported CMS' plan to remove five measures from the Inpatient Quality Reporting program, including one for death among surgical inpatients with serious treatable complications, also known as Patient Safety Indicator 4. CMS claimed that measure would no longer be necessary since its proposed Hybrid Hospital-wide All-cause Mortality Measure captures 30-day mortality for more conditions and procedures and includes both claims and clinical data.
But purchasers and consumer advocates said the new measure might not be a perfect substitute, which could leave Medicare beneficiaries in the dark about the quality issues that are most important to them.
"The Hybrid Hospital-Wide All-Cause Risk Standardized Mortality measure is not a replacement for PSI-4 because many hospital deaths are not related to preventable safety problems. Deaths counted in PSI-4 can be prevented by hospitals; deaths from all causes are not always the fault of the hospital," The Leapfrog Group said in a comment letter cosigned by dozens of other organizations and advocates.
Hospitals generally supported the new all-cause mortality measure but urged CMS to make it voluntary for the time being.
"In concept, the use of EHR data has the potential to bring much more precise clinical information to measures than using claims data alone. It could enhance risk adjustment approaches and make the measure much more accurate. Yet, we are concerned that the experience with reporting such a measure has been far too limited for CMS to deem the measure ready for the more than 3,500 hospitals that would be required to report it," AHA wrote.
If CMS makes reporting the new measure voluntary, it could keep its separate measure for death among surgical inpatients, given that the new all-cause measure was supposed to replace it.
