CMS’ Star Ratings Miscalculated

Modern Healthcare is reporting that the Centers for Medicare and Medicaid Services (CMS) has miscalculated hospitals star ratings since they were first released in 2016 (1). Officials at Rush University Medical Center in Chicago exclusively disclosed their analysis and correspondence to Modern Healthcare. The investigators found that instead of evenly weighting the eight measures in the safety of care group, the CMS' star ratings formula relied heavily on one measure— The Patient Safety and Adverse Events Composite, known as PSI 90 —for the first four releases of the ratings and then complication rates from hip and knee replacements for the latest release. The single measure accounted for about 98% of a hospital's performance in the safety group, according to Rush's analysis. The safety group can also greatly influence a hospital's overall star rating, the analysis concluded. Rush's findings likely prompted the CMS to announce this week that it would postpone the July release of its star ratings (1).

The statistical model the CMS uses likely caused the miscalculation. The model, called latent variable modeling, uses scores for seven groups of measures to calculate the star ratings:

1. Mortality
2. Safety of Care
3. Readmission
4. Patient Experience
5. Effectiveness of Care
6. Timeliness of Care
7. Efficient Use of Medical Imaging

The three outcome groups—mortality, safety and readmissions—are each weighted the most at 22% each. Measures within each group are supposed to be evenly weighted to calculate the hospital's performance in that area. Rush's analysis found that the weight given to the PSI-90 measure was much greater than the seven other measures in the safety group. Specifically, PSI-90 was weighted 1,010 times stronger than the catheter-associated urinary tract infections measure, 81 times stronger than the C. difficile infection rates measure, 51 times stronger than the central line-associated bloodstream infection rates measure and 20 times stronger than either the surgical site infection rate measure.

Latent variable modeling changes the weighting and is inappropriate for measuring clinical outcomes, said David Levine, senior vice president of advanced analytics and informatics at Vizient (1). "Given the disproportionate weighting of the safety scores over time, they did not represent a composite measure," said Dr. Omar Lateef, an author of the analysis and Rush's senior vice president and chief medical officer (1). Lateef said he and his colleagues at Rush were alarmed by a rating drop from 5 to 3 stars because they have improved performance on five of the eight safety measures since the December release. " Lateef added that although CMS was initially dismissive of Rush’s concerns that CMS has come around since presented with Rush’s analysis.

CMS announced earlier this week that it was delaying release of the star ratings "to address stakeholders concerns." No date has been set for when the new ratings will be released.

Richard A. Robbins, MD

Editor, SWJPCC

Reference

1. Maria Castellucci M. CMS star rating system has been wrong for two years, health system finds. Modern Healthcare. June 15, 2018. Available at: http://www.modernhealthcare.com/article/20180615/TRANSFORMATION01/180619933?utm_source=modernhealthcare&utm_medium=email&utm_content=20180615-TRANSFORMATION01-180619933&utm_campaign=am (accessed 6/15/18).

Cite as: Robbins RA. CMS' star ratings miscalculated. Southwest J Pulm Crit Care. 2018;16(6):338-9. doi: https://doi.org/10.13175/swjpcc078-18 PDF 

CMS Announces New Payment Model

On Tuesday, 1/9/18, the Centers for Medicare and Medicaid (CMS) announced a new voluntary bundled-payment model that will be considered an advanced alternative payment model under Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) (1). The new model is the first advanced Alternative Payment Model (APM) to be introduced by the Trump administration. The Trump administration has been a vocal advocate of reducing administrative burden for clinicians and has touted voluntary models as a solution (2). The new, voluntary model comes less than two months after the CMS officially decided to eliminate two mandatory bundled-payment models created during the Obama administration.

Under the model, clinician payment will be based on quality measures during a 90-day episode of care. Participants must select at least one of the 32 clinical episodes to apply to the model. The inpatient clinical episodes are listed in Table 1 (3).

Table 1. Clinical inpatient episodes under proposed payment model.

• Acute myocardial infarction
• Back & neck except spinal fusion
• Cardiac arrhythmia
• Cardiac defibrillator
• Cardiac valve
• Cellulitis
• Cervical spinal fusion
• COPD, bronchitis, asthma
• Combined anterior posterior spinal fusion
• Congestive heart failure
• Coronary artery bypass graft
• Double joint replacement of the lower extremity
• Fractures of the femur and hip or pelvis
• Gastrointestinal hemorrhage
• Gastrointestinal obstruction
• Hip & femur procedures except major joint
• Lower extremity/humerus procedure except hip, foot, femur
• Major bowel procedure
• Major joint replacement of the lower extremity
• Major joint replacement of the upper extremity
• Pacemaker
• Percutaneous coronary intervention
• Renal failure
• Sepsis
• Simple pneumonia and respiratory infections
• Spinal fusion (non-cervical)
• Stroke
• Urinary tract infection

Providers will be eligible for bonuses based on their performance. For more information about the model and its requirements, or to download a Request for Applications document (RFA), the application template, and the necessary attachments, please visit: https://innovation.cms.gov/initiatives/bpci-advanced. Applications must be submitted via the Application Portal, which will close on 11:59 pm EST on March 12, 2018. Applications submitted via email will not be accepted.

The CMS Innovation Center will hold a Q&A Open Forum on Tuesday, January 30, 2018 from 12 pm – 1 pm EDT. This event is open to those who are interested in learning more about the model and how to apply. Please register in advance here - https://preaward.adobeconnect.com/e3cdwg6hgx9f/event/registration.html.

Richard A. Robbins, MD

Editor, SWJPCC

References

1. Centers for Medicare and Medicaid Services. CMS announces new payment model to improve quality, coordination, and cost-effectiveness for both inpatient and outpatient care. January 9, 2018. Available at: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-releases/2018-Press-releases-items/2018-01-09.html (accessed 1/10/18).
2. Castellucci M. CMS launches new voluntary bundled-payment model. Modern Healthcare. January 9, 2018. http://www.modernhealthcare.com/article/20180109/NEWS/180109905 (accessed 1/10/18).
3. Centers for Medicare and Medicaid Services. BPCI Advanced. January 9, 2018. Available at: https://innovation.cms.gov/initiatives/bpci-advanced (accessed 1/10/18).

Cite as: Robbins RA. CMS announces new payment model. Southwest J Pulm Crit Care. 2018;16(1):29-30. doi: https://doi.org/10.13175/swjpcc006-18 PDF 

Banner Prints Social Security Numbers

The Monday edition of the Arizona Republic contained a story with potential interest to our readers. On the most recent address labels of Banner Health's magazine, Smart & Healthy, the addressee's Social Security or Medicare identification numbers, which are often identical to their Social Security numbers (1). The magazine was mailed to more than 50,000 recipients in Arizona late last week.

The recipients are members of the Medicare Pioneer Accountable Care Organization, a government health-care plan that Banner serves. Banner generated its mailing list from information it received from the U.S. Centers for Medicare & Medicaid Services, which is an agency within the U.S. Department of Health & Human Services (HHS) responsible for administration of several federal health-care programs.

Although medical information has been protected by the Health Insurance Portability and Accountability Act (HIPAA) since 1996, penalties were recently increased. Civil monetary penalties were increased from a maximum of $100 to $50,000 per violation and the maximum aggregate increased from $25,000 for each violation to $1,500,000 per year. If multiple violations occur the penalties could exceed $1,500,000. Reflecting the increase in penalties, HHS fined BlueCross Blue Shield (BC&BS) of Tennessee $1.5 million in a case involving a breach that affected more than 1 million individuals (2). Locally, HHS fined a Phoenix cardiac surgery group $100,000 for posting patients' appointment information on an internet calendar that was available to the public (2).

Officials at HHS and Social Security Administration are looking into the matter (1). The $100,000 fine of the physician group in Arizona is likely a fairly sizable portion of their revenue. In contrast, the $1.5 million penalty paid by Tennessee BC&BS is less than 0.03% of their $5.6 billion revenue (3). Banner had total revenues of $4.9 billion and assets of $7.6 billion in 2012.

Richard A. Robbins, MD

References

1. Giblin P. Medicare IDs erroneously published. Arizona Republic. Available at: http://www.azcentral.com/news/arizona/articles/20140224medicare-ids-erroneously-published.html (accessed 2/27/14).
2. Anderson H. Arizona practice gets $100k HIPAA fine. Available at: http://www.govinfosecurity.com/arizona-practice-gets-100k-hipaa-fine-a-4686 (accessed 2/27/14).
3. Flessner D. BlueCross BlueShield of Tennessee earns record $221 million. Chattanooga Times Free Press Available at: http://www.timesfreepress.com/news/2013/apr/30/bluecross-earns-record-221-million/?business (accessed 2/27/14).
4. Ernst & Young. Banner Health Consolidated Financial Statements. Available at: https://www.bannerhealth.com/NR/rdonlyres/DD3E9650-00D6-4385-B12B-E96BBC4E9917/67703/_BannerHealthconsolidated201211_Final.pdf (accessed 2/27/14).

Reference as: Robbins RA. Banner prints social security numbers. Southwest J Pulm Crit Care. 2014;8(2):140-1. doi: http://dx.doi.org/10.13175/swjpcc027-14 PDF

Many Southwest Hospitals Will Receive Decreased CMS Reimbursement

More hospitals are receiving penalties than bonuses in the second year of the Centers for Medicare and Medicaid Services' (CMS) quality incentive program, and the average penalty is steeper than last year according to a report from Jordan Rau in Kaiser Health News (1). Southwest hospitals reflect that trend with New Mexico and Arizona exceeding the US average both in percentage of hospitals receiving penalties and the average size of the penalty (Table 1). Colorado approximated the national averages (Table 1).

Table 1. Hospital CMS reimbursement bonus/penalty 2014. (For individual hospitals see Appendixes for Arizona, Colorado, New Mexico, and the Mayo Clinic Minnesota).

Most hospitals are gaining or losing <0.2% but in some instances the penalties are substantial. Gallup Indian Medical Center in New Mexico, a federal government hospital on the border of the Navajo Reservation, will be paid 1.14 percent less for each patient and New Mexico’s average of a -0.31% decline in reimbursement are the largest changes nationally. 

“This program is driving what we want in health care,” said Dr. Patrick Conway, CMS’ chief medical officer. He said most hospitals have improved since the program began a year ago despite more hospitals receiving penalties than bonuses. However, even some hospitals that have gotten better are still losing money because they are not scoring as well as others or have not improved as much.

Most winners from last year stayed winners and losers stayed losers, but there were some switches. For example, Banner Boswell Medical Center in Sun City will receive a 0.36% bonus in place of a -0.58% penalty last year. In contrast, the University of Colorado will receive a -0.35% penalty this year compared to a bonus of 0.29% last year. 

This year 45% of a hospital’s change in CMS reimbursement is based process of care measures. Patient satisfaction accounts for 30%. However, for the first time 25% of the score is based on standardized mortality for myocardial infarction, heart failure and pneumonia. CMS is planning to add new measures next year, including comparisons of charges at different hospitals and rates of medical mishaps and infections from catheters.

The maximum readmission penalties grow to 3% next year and CMS is launching a third incentive program that takes an additional 1 percent of payments away from hospitals with the most patients who suffered injury or infection during their stay. Combined, these measures have the potential to strip away as much as 5.5 percent of CMS payments from the worst performing hospitals starting next October.

As reported in the Southwest Journal of Pulmonary and Critical Care Southwest hospital charges to CMS vary widely for pulmonary and critical care DRGs (2). Also, the complications chosen by CMS do not correlate with outcomes (3). Felton et al. (4) reported higher patient satisfaction was associated with higher admission rates to the hospital, higher overall health care expenditures, and increased mortality and not the expected improvements in outcomes.

Ashish Jha (5) from the Harvard School of Public health examined the latest CMS reimbursement data and reported in his blog that hospitals in the West receiving larger penalties than other areas. Most disturbingly, public hospitals and safety-net hospitals also tended to do worse. As Jha points out these penalties are not large but the change may be relevant for a safety-net hospital operating on a small financial margin.

Richard A. Robbins, MD

References

1. Rau J. Nearly 1,500 hospitals penalized under Medicare program rating quality. Available at: http://www.kaiserhealthnews.org/stories/2013/november/14/value-based-purchasing-medicare.aspx (accessed 11/19/13).
2. Robbins RA. Variation in southwestern hospital charges for pulmonary and critical care DRGs. Southwestern J Pulm Crit Care. 2013;7(1):31-7. [CrossRef]
3. Robbins RA, Gerkin RD. Comparisons between Medicare mortality, morbidity, readmission and complications. Southwest J Pulm Crit Care. 2013;6(6):278-86.
4. Fenton JJ, Jerant AF, Bertakis KD, Franks P. The cost of satisfaction: a national study of patient satisfaction, health care utilization, expenditures, and mortality. Arch Intern Med 2012;172:405-11. [CrossRef][PubMed]
5. Jha AK. An update on value-based purchasing: year 2. Available at: https://blogs.sph.harvard.edu/ashish-jha/ (accessed 11/19/13).

Reference as: Robbins RA. Many southwest hosptials will receive decreased CMS reimbursement. Southwest J Pulm Crit Care. 2013;7(5):305-6. doi: http://dx.doi.org/10.13175/swjpcc164-13 PDF