• CMS Selects 800 Hospitals for Calendar Year 2012 Outpatient Record Validation Under the Hospital Outpatient Data Quality Reporting Program
  • December 8, 2010 | Author: Stephanie A. Webster
  • Law Firm: King & Spalding LLP - Washington Office
  • On December 1, 2010, CMS published its list of the 800 hospitals selected for chart validations under the hospital outpatient prospective payment system data quality reporting program (HOP QDRP).  CMS had formerly requested outpatient quality data from all hospitals, but has now determined to review data from only 800 randomly selected hospitals.  The results of this validation will affect the payment rates for only the 800 hospitals for calendar year 2012.

    The HOP QDRP is a quality data reporting program implemented by CMS under Section 109(a) of the Medicare Improvements and Extension Act, Division B of the Tax Relief and Health Care Act of 2006 (MIEA-TRHCA), which corresponds to Section 1833(t) of the Social Security Act.  Under the HOP QDRP, hospitals report data using standardized measures of care in order to receive the full annual payment update (APU) to their outpatient prospective payment system payment rate.  Hospitals that fail to report data to CMS incur a 2.0 percentage point reduction to their APU, which applies to the payment year to which the survey data relates.

    In its Proposed Rule published on August 3, 2010, CMS proposed to validate data submitted by 800 hospitals for purposes of the CY 2012 HOP QDRP payment determination.  CMS also proposed to retain the 11 quality measures for CY 2012 determination as well as to add one new structural measure and three new claims-based imaging efficiency measures.  In its Final Rule published on November 24, 2010, CMS finalized its proposal to review medical records from only 800 of the HOP QDRP participating hospitals.  CMS also decided to adopt its proposal regarding the addition of the four new HOP QDRP reporting for calendar years 2012.

    For the CY 2012 payment update, CMS decided to validate data for only 800 hospitals out of the approximately 3,200 HOP QDRP participating hospitals.  CMS commented that this approach would produce a more reliable estimate of whether a hospital’s submitted data has been abstracted accurately; would provide more statistically reliable estimates of the quality of care delivered in each selected hospital as well as at the national level; and would reduce overall hospital burden because most hospitals will not be selected to undergo validation each year.  CMS will request no more than twelve medical records per hospital per quarter from the 800 selected hospitals.