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CMS Finalizes Changes to VBP Due to Pandemic

September 9, 2021

CMS provided the FY 2022 IPPS Final Rule, which provides guidance on the use of CY2020 HCAHPS data for Value Based Purchasing (VBP). Previously, we learned that CMS was not going to use the Q1 2020 or Q2 2020 data in VBP, the submission of which was optional. If you want to read the full text of the final rule, including submitted comments and CMS’ responses, you can access it here.

In this rule, CMS finalized their proposal to not provide Total Performance Scores (TPS) for hospitals for FY2022 (meaning, this would go into effect for payments beginning October 2021). As proposed, they will instead provide each hospital a value-based incentive payment amount to equal the required two percent reduction to the base operating DRG payment amount—in effect, making the payment adjustment neutral.

Other proposals that were finalized in this rule include:

  • For FFY2022—Suppressing HCAHPS, Medicare Spending Per Beneficiary (MSPB), five Healthcare-Associated Infection (HAI) measures
  • Providing confidential feedback reports to hospitals on FY 2022 for all measures
  • Publicly reporting Q3 2020 and Q4 2020 data with disclaimers surrounding the COVID-19 public health emergency (PHE)
  • For FFY 2023, suppressing only one measure, MORT30-PN (Pneumonia 30 Day Mortality Rate)
  • PSI 90 was removed from VBP in FFY2019, and scheduled to be re-added in FFY2023. However, CMS is now again removing the measure from the Hospital VBP Program
  • For FFY 2024, for the HCAHPS, Efficiency and Safety Domains, adjusting the baseline period to be CY2019 instead of Jul-Dec 2020 as previously described. These baseline periods will match what was used for FFY 2023

They also published information showing how the COVID-19 PHE has affected HCAHPS scores nationally—they compared a hospital’s adjusted scores from the same quarter in different years, and saw that prior to the pandemic, scores generally increased through time with changes of less than one top-box point. During Q2 2020 and Q3 2020, compared to Q2 2019 and Q3 2019, they saw much larger changes—negative, and with several measures having decreases of one to three points on the top-box score. More information about this is available here.

In the future, CMS will also provide information on refreshes to the Overall Hospital Star Ratings and HCAHPS Star Ratings, since only Q3 and Q4 2020 are scheduled to be publicly reported.