Recap of 2011
As 2011 comes to a close it is useful to reflect on how far we have come in a year. It is also relevant to project what 2012 has in store and what QMS is doing to ensure that our clients are ready to address these new challenges.
A year ago - year's end 2010 - we were generating claims under the old "composite rate - case mix" rules with complex reporting of ESAs (EE, ED, and GS modifiers) but getting ready for a whole new paradigm, particularly for those that chose to go with 100% bundling. During the first quarter of 2011, modified claims were generated - expanded by the need to include labs and complicated by the need for timely electronic population of the claim file from lab contractors. With a few hiccups and some claim submission delays, QMS clients were able to generate a reliable revenue stream. Clinical practice quickly responded to the need to optimize clinical management (such as judicious use of ESAs) and tools available in QCS facilitated this optimization. Capture of co-morbidities was also critical using QCS. Also, Accounts Receivable tracking needed to account for the revenue "tail" associated with acute co-morbidities. As 2011 comes to a close the revenue and optimization aspects of client businesses seem to be stabilizing and are producing better results than were expected a year ago.
New Challenges of 2012
As 2012 starts there are new challenges and requirements to address. The 5010, ICD-10, and QIP need to be rapidly addressed. Note that QIP metrics for payment adjustments in 2014 will be evaluated based on Calendar Year 2012 performance. There is also the concern for the rollout of CROWNWeb, which CMS believes will happen this year (see below). Our top priority is to prepare our clients for a smooth transition to these new regulations.
QIP: 2012 through 2014
QIP criteria for payment year 2012 (PY2012) were released as part of the final bundling rule in August of 2010. There are three criteria for possible payment reduction for PY2012: hemoglobin (Hgb) > 12 g/L (25% weighting); Hgb < 10 g/L (50% weighting); and URR > 65% (25% weighting). The performance period for this evaluation was calendar year 2010 (CY2010). Facilities have been “graded” by CMS and the levels of payment reduction have been sent to providers. We have incorporated these payment reductions in our AR systems in QMS Focus.
QIP criteria for PY2013 have been changed with the Hgb < 10 g/L eliminated. The remaining PY2012 metrics: Hgb > 12 g/L and URR > 65% have been retained. For PY2013 the performance period is CY2011.
The recently proposed criteria for PY2014 were released in the summer of 2011 and the final rules were published in November. Of the eight originally proposed metrics six have been retained (below in bold):
• Hgb > 12 g/L. Grading weight: 30% of total points
• URR > 65% (This metric, which was intended to be changed to Kt/V was retained for PY2012 because of the currently differing methods of evaluating Kt/V). Grading weight 30% of total points
• Vascular access type (VAT). Grading weight 30% of total points.
• Vascular access infection – dropped as a metric
• Standard hospitalization ratio – dropped as a metric
• NHSN – infection reporting to the Centers for Disease Control: enrollment, training of clinical personnel, and entry of 3 months of data. Grading weight 3.33% of total points for enrollment, training, and data entry; 1.67% of total points for enrolling, training, but no data entry.
• CAHPS – patient satisfaction survey of all patients. Grading weight 3.33% of total points.
• Ca ++ /P – Performing monthly measurements (no target values) on all patients for the year. Grading weight 3.33% of total points.
90% of the total grade consists of clinical metrics currently being reported on CMS claim forms generated in QMS Focus: Hgb, URR, and V A T. The remaining three items (representing 10% of the total points) will be evaluated by clinical “attestation”, which doesn't have to be reported until 2013, March 31, 2013 for NHSN; January 31, 2013 for CAHPS and Ca ++ /P. Means for attestation for the non-clinical criteria is intended to be via CROWNWeb (see below).
QIP: New capabilities for QMS clients to evaluate their compliance with QIP
As stated above the clinical metrics for QIP for all performance periods currently announced are being reported on Medicare claims generated by QMS systems. We have added a major new capability to permit QMS clients to track performance related to QIP so that all QMS users have real time access to their status and areas for increased clinical attention as performance data are collected throughout 2012. We feel that the reporting and analytical capabilities now available will help our clients effectively address the new challenges of meeting QIP requirements. If you need to learn the details of this capability please contact us.
Data Submission – CROWNWeb and Health Information Exchanges (HIEs)
CMS has been in the process of developing CROWNWeb, an ESRD data collection system, for approximately five years. In its initial form it was intended to be a manual data entry system whereby dialysis clinics would periodically enter clinical and demographic data on their patients and staff. The vision continues to be one of manual entry by individual clinics. Its rollout has been continually delayed over the past few years, in many cases because of the significant burden that it imposed on provider staff, but also because of the expanding scope of data included in the CROWNWeb data set as well as the changing CMS regulations.
The concern of QMS is the significant inefficiency of taking data in an electronic format and currently collected by QCS and manually reentering them via a key board into the CMS database. We have communicated this concern to CMS for well over two years and have fully supported the National Renal Administrators Association (NRAA) in its effort to provide electronic submission to CROWNWeb from electronic clinical systems such as QCS.
In the summer of 2011, the NRAA mounted an industry project for such electronic submission through a Health Information Exchange (HIE) and QMS has been a key partner in this initiative. The project is going forward in 2012 with the goal of conducting pilot demonstrations and making this capability available to providers with appropriate electronic data systems. QMS is fully involved and, with QCS, will be providing this functionality to its clients.
CROWNWeb: Anticipated Rollout
CMS has announced the rollout of the CROWNWeb system early in 2012. This is the current target although as stated above it is just the “current” target. The NRAA has strived to have this rollout, of what is effectively a manual entry system, delayed until electronic entry means are available so that providers can avoid the large burden that such a manual data entry system will have on its staff. It appears from wording in the text of the final QIP rules that, in fact, CMS anticipates significant delays during 2012. This inference derives from delaying attestation of non-clinical criteria to 2013 as well as several responses to comments in the QIP final report to this effect. Discussing the methods to be used for attestation CMS 's comments in the QIP rules:
“ CROWNWeb is on schedule for national release in CY 2012 which will allow providers/facilities to report their attestation by the January 2013 deadline. We do recognize, however, that unanticipated delays may occur. Therefore, if CROWNWeb will not be available in time for the January 30, 2013 [C A HPS] attestation deadline, we will adopt an alternative, electronic mode of attestation and notify providers/facilities of this method through the ESRD Networks. * ”
QMS will be monitoring the CROWNWeb project as the HIE effort goes forward and will keep QCS clients abreast of capabilities for electronic submission of CROWNWeb data as 2012 progresses.
* See pages 159 and 163-164 of the QIP final rules
QCS: Year in Review
As clients expand the dialysis services they provide, QCS has expanded its capabilities as well. In addition to helping clients manage the complexity of QIP and prepare for the CROWNWeb data submission requirements, QCS now offers significant enhancements in the area of home therapy. Enhanced documentation of nocturnal Hemodialysis treatments to provide optimal tracking of this specific treatment was a key feature added to the application in 2011. Additionally the QCS PD module was enhanced to provide more comprehensive charting, more efficient and versatile medication documentation, along with a focus on design as it relates to the clinical intake flow of the PD care team.
In 2011 QMS introduced Customized Forms a feature designed to make QCS more flexible and better able to address client specific client needs. Forms can now be built with a design screen that allows the customization of text fields, dropdown boxes, and data lists. Additionally, formatting features are available providing tools such as different fonts, size, and attributes to fields that are able to pull data from elsewhere in QCS specified by the clients. Once designed the forms can be completed, signed and stored entirely within QCS as a part of the patient's clinical record, or they can be printed before or after being completed as the client sees fit.
QMS has expanded documentation capabilities to allow the facility/user to generate a library of common phrases to function as text templates to increase efficiency and consistency while reducing the burden of accurate documentation. QCS has built on the existing capability to create and apply facility and/or user specific Common Phrases as text templates throughout the application. Users can now use common phrases to increase efficiency and consistency in documentation in multiple areas in QCS, such as Progress Notes screen and Patient Rounding screen.
Back to the Top
Still Have Questions?
QMS hopes that the above information is useful as you take on the new year. We greatly appreciate your business and look forward to working with you in 2012.
Please do not hesitate to contact us if you have any questions or concerns. We can be reached at 1-800-752-4600 or you can e-mail us at qms@qms-us.com .
Back to the Top