Medicare: BIO's Comments on Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Fiscal Year 2014 Rates

Re: Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Fiscal Year 2014 Rates; Quality Reporting Requirements for Specific Providers; Hospital Conditions of Participation [CMS-1599-P]

Dear Administrator Tavenner:

The Biotechnology Industry Organization (BIO) appreciates this opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS) Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective

Payment System and Proposed Fiscal Year 2014 Rates Proposed Rule (“the Proposed Rule”), specifically the Hospital Inpatient Quality Reporting (IQR) Program and the Hospital Value-Based Purchasing (VBP) Program.[1]  BIO represents more than 1,100 biotechnology companies, academic institutions, state biotechnology centers, and related organizations across the United States and in more than 30 other nations.  BIO members are involved in the research and development of innovative healthcare, agricultural, industrial, and environmental biotechnology products. 

BIO membership includes biologics and vaccine manufacturers and developers who have worked closely with stakeholders across the spectrum, including the public health and advocacy communities, to support policies that help ensure access to innovative and life-saving medicines and vaccines for all individuals.  BIO supports the development and use of appropriate, evidence-based quality measures throughout the healthcare system as a component of improving efficiency, short- and long-term clinical outcomes, and overall patient health.  Immunization quality measures, as one example, help ensure that healthcare providers routinely discuss and offer recommended vaccines to their patients, resulting in higher vaccine uptake, better health outcomes, and cost savings for the healthcare system. 

Our comments focus on several quality measures proposed for inclusion or amendment in the Hospital IQR Program and the Hospital VBP Program.  Discussed in detail below, we ask that CMS: 

1. Finalize the provision to include the influenza immunization measure for acute care hospitalized inpatients age 6 months or older (IMM-2, National Qualify Forum [NQF] #1659) in the Hospital VBP Program;
2. Reconsider the proposed removal of the pneumonia immunization measure (IMM-1) from the Hospital IQR Program, as this could adversely affect pneumococcal immunization rates, public health, and patient safety;
3. Finalize the provision to include Chronic Obstructive Pulmonary Disease (COPD) readmission and mortality rate measures in the Hospital IQR Program;
4. Include the American Heart Association(AHA)/American Stroke Association (ASA) Stroke (STK) measure set in the Hospital VBP Program, similar to its previous incorporation into the Hospital IQR Program, as a complimentary component of a broader set of measures that reflect the treatment continuum of stroke patients;
5. Finalize the proposal to move “drip and ship” cases (those in which Tissue Plasminogen Activator (tPA) (rtPA) administration occurs within 24 hours prior to admission) to a higher Medicare severity diagnosis-related group (MS-DRG) as a move toward recognizing the costs for comprehensive stroke care;
6. Finalize the proposal to expand the collection of central line associated blood stream infection (CLABSI) data to select non-intensive care unit (non-ICU) locations, and identify potential sources of variation leading to unreliable and inconsistent reporting of infection data; and
7. Finalize the proposed inclusion of a standardized infection ratio of hospital-onset Clostridium difficileInfection (CDI) in the Long-Term Care Hospital Quality Reporting (LTCHQR) Program and include this measure in the Hospital VBP Program as well.