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FFY2023 HCAHPS Proposed Rule Published

April 22, 2022

In a recent proposed rule, CMS announced several changes to Value Based Purchasing (VBP) for HCAHPS due to observations about data collected during the pandemic.

Similar to the finalized rule last year for FFY2022, for FFY2023 (affecting October 2022 payments), CMS is proposing to suppress several VBP measures and implement a special scoring methodology that results in each hospital receiving a value-based incentive payment amount that matches their 2 percent reduction to the base operating DRG payment amount —in effect, making the payment adjustment neutral.

CMS has also conducted analyses on the VBP Program measures to examine the impact of the pandemic on those measures. Based on that, they propose to suppress the following measures for FFY2023:

  • Person and Community Engagement: HCAHPS
  • Safety: Healthcare-Associated Infections
    • Catheter-Associated Urinary Tract Infection (CAUTI) Outcome Measure
    • Central Line-Associated Bloodstream Infection (CLABSI) Outcome Measure
    • Specific Surgical Site Infection (SSI) Outcome Measure
    • Methicillin-resistant Staphylococcus aureus (MRSA) Bacteremia Outcome Measure
    • Clostridium difficile Infection (CDI) Outcome Measure
  • Clinical Outcomes: Mortality Measures
    • Hospital 30-Day, All Cause, Risk Standardized Mortality Rate Following Pneumonia (PN) Hospitalization measure (MORT-30-PN) (previously suppressed in the FY 2022 IPPS/LTCH PPS final rule)

The non-suppressed Clinical Outcome measures and the Efficiency measure would still have achievement and improvement points calculated, but no Total Performance Scores (TPS) would be calculated.

They also propose to continue to use a baseline period of CY2019 for the FFY2025 (performance period: CY2023) program year for HCAHPS (this would result in the same achievement thresholds and benchmarks as we saw for FFY2023 (performance period: CY2021) and FFY2024 (performance period: CY2022)).

They also released quarter-over-quarter data so we can compare national hospital performance during the pandemic. That information can be viewed here.

Finally, if the proposal to not calculate TPS scores for VBP for FFY2023 is finalized, facility-based measurement would be unavailable for MIPS eligible clinicians to whom that hospital’s TPS would be applicable. Providers who would normally be evaluated through facility-based measurement would need to use a different measure in MIPS for the CY 2022 MIPS performance period/CY 2024 MIPS payment year or apply to reweight their performance categories.

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. If you have more questions about this proposed rule, please reach out to our CAHPS® team at [email protected].