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CMS Proposes Changes to VBP as a Result of the Pandemic

May 13, 2021

CMS provided the FY 2022 IPPS Proposed 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 proposed rule, you can access it here.

In this rule, CMS proposes not providing Total Performance Scores (TPS) for hospitals for FY2022 (meaning, this would go into effect for payments beginning October 2021), but providing each hospital a value-based incentive payment amount to equal the required 2 percent reduction to the base operating DRG payment amount—in effect, making the payment adjustment neutral.

Other proposals include:

  • Suppressing all measures for VBP FFY2022 except for Clinical Outcomes
  • 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 readded in FFY2023. However, CMS is now proposing to remove 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

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.

CMS welcomes comments on any of this information, which may be submitted via http://www.regulations.gov by following the instructions under the “submit a comment” tab. Comments must be submitted by 5 pm EDT on June 28, 2021.