Thursday, August 8, 2013

Predicting Avoidable 30-Day Readmissions




Article Info :

By: Jacques Donzé, MD,

 

References: 

Donzé J, Aujesky D, Williams D, Schnipper JL. Potentially avoidable 30-day hospital readmissions in medical patients: derivation and validation of a prediction model. JAMA Intern Med.






 

Predicting Avoidable 30-Day Readmissions

 

For medical patients, a simple prediction model appears to identify the risk of potentially avoidable early readmissions before discharge. The model can help clinicians seek out patients who may need more intensive transitional care interventions.

Throughout the United States, readmission rates are increasingly being used for benchmarking across hospitals. Some hospital readmissions may be avoidable, which in turn has led to the levying of financial penalties on hospitals with high risk-adjusted rates. Recent studies have estimated that the 30-day readmission rate for Medicare beneficiaries is almost 20%, and these occurrences cost the U.S. healthcare system as much as $17 billion annually.

In June 2009, CMS began publishing 30-day readmission data for select medical diseases, resulting in hospital readmissions becoming an important metric for measuring the quality of patient care. The changing regulations issued by CMS means that hospital reimbursements can be reduced based on an adjustment factor determined by a hospital’s expected and observed 30-day readmission rates. These changes have also raised the bar for decreasing unnecessary surgical readmissions. In addition to the financial implications, unplanned hospital readmissions further limit hospital resources. For each patient readmitted, there is an opportunity lost to treat another patient who needs care.

 

New Prediction Model for 30-Day Readmission In JAMA Internal Medicine, Dr. Donzé and colleagues had a study published that derived and validated a prediction model for potentially avoidable 30-day hospital readmissions in medical patients. The model used administrative and clinical data that was readily available prior to discharge. “Our purpose was to help clinicians target transitional care interventions most efficiently,” Dr. Donzé says. “The goal was to develop a score to predict potentially avoidable readmissions. In other words, we wanted to predict which patients may be most likely to benefit from intensive interventions.” The HOSPITAL score is able to indicate readmission risk before a patient is discharged. This allows clinicians to target a timely transitional care intervention. In their retrospective analysis, Dr. Donzé and colleagues analyzed potentially avoidable 30-day readmissions at three hospitals using a validated computerized algorithm. Several factors were identified as being independently associated with the risk of potentially avoidable readmission.

These factors were then used to build a prediction score—referred to as the HOSPITAL score—for early readmission: hemoglobin at discharge; discharge from an oncology service; sodium level at discharge, procedure during the index admission; index type of admission; number of admissions during the last 12 months; and length of stay (Table 1). “The strength of the HOSPITAL score is its simplicity,” says Dr. Donzé.

 “Physicians can easily review these seven variables at a patient’s bedside prior to discharge. The more of these risk factors a patient has, the greater the risk of readmission. If a patient is deemed high risk for readmission, a return trip to the hospital could be prevented by offering additional interventions, such as a home visit from nurses, patient coaching, or a pharmacist consultation.” Validating Results on the HOSPITAL Score Using the HOSPITAL score, Dr. Donzé and colleagues stratified the risk of potentially avoidable readmission into three categories: low, intermediate, and high. Low-risk patients, who scored between 0 and 4 points, had a 5.2% estimated risk of potentially avoidable readmission.

The observed proportion in the derivation set was 5.4%. High-risk patients, who scored 7 or higher on the HOSPITAL score, had an estimated probability of potentially avoidable readmission of 18.3% and an observed probability of 18.7% (Table 2). When compared with other prediction models, Dr. Donzé says the HOSPITAL score had fair discriminatory power and good calibration in identifying the risk of potentially avoidable readmission.

“The HOSPITAL score was developed to identify readmissions that might be prevented and are therefore potentially actionable,” he says. “It can be used for all medical patients regardless of their primary cause of admission. Perhaps most important is the fact that the HOSPITAL score is able to indicate readmission risk before a patient is discharged. This allows clinicians to target a timely transitional care intervention.” The HOSPITAL score can be a valuable tool in the national effort to reduce healthcare costs and improve the quality of care, according to Dr. Donzé. “Identifying patients who at least have the potential to benefit from more intensive transitional interventions is an important first step in reducing hospital readmissions. All patients should receive high-quality transitional care that meets certain standards. We’re not recommending that low- and average-risk patients be deprived of effective transitional interventions. That said, certain interventions that have been shown to be successful are resource intensive. One way to make the best use of limited resources is to reserve them for those who are most likely to benefit from them.” Validating Readmissions Prediction Model Although the HOSPITAL model is promising, no prediction model will be a perfect indicator of preventable readmissions. Because the model was created and validated at one hospital, a multicenter international validation of the model is currently underway. “Predicting potentially avoidable readmissions is only a proxy for identifying who might benefit from specific interventions,” says Dr. Donzé. “Studies of interventions that target this patient group are needed to definitively prove the usefulness of the HOSPITAL score.

 

Patients at Highest Risks for Readmission Based on analysis of ICD-9 coding data, Dr. Sweeney and colleagues found that gastrointestinal complications carried a high risk of readmission (27.6%), while surgical infections reached 22.1%. These top two reasons accounted for nearly half of all readmissions, according to study findings. Complex gastrointestinal procedures, such as pancreatectomy, colectomy, and liver resection, likely had higher complication rates because of the complexity of these surgeries. The top surgical complications identified in the study were wound infections, pulmonary complications, and urinary tract infections (UTIs). Patients with postoperative sepsis or UTIs were about five times more likely to be readmitted than patients without these complications. Postoperative wound infections and postoperative pulmonary complications were associated with a 3.5-fold increase in readmission rates. Additionally, several comorbidities substantially affected readmission risk, most notably cancer, open wounds, and dyspnea. Patients who were immunosuppressed, poor wound healers, and with baseline pulmonary disease were also vulnerable to complications that raise the likelihood of postoperative readmission.

2013 Physician Quality Reporting System (PQRS)


 2013 Physician Quality Reporting System (PQRS):

 

 The Physician Quality Reporting System (PQRS) is a voluntary reporting program that provides an incentive payment to identified eligible professionals who satisfactorily report data on quality measures for covered Physician Fee Schedule (PFS) services furnished to Medicare Part B Fee-for-Service (FFS) beneficiaries (includes Railroad Retirement Board and Medicare Secondary Payer).

 Beginning in 2015, the program also applies a payment adjustment to eligible professionals who do not satisfactorily report data on quality measures for covered professional services.

 

Electronic Health Record Reporting

Beginning with the 2010 Physician Quality Reporting System (PQRS) program year, eligible professionals may qualify to earn a PQRS incentive through the Electronic Health Record (EHR)-based reporting method.  Eligible professionals (EPs) have the following EHR-based reporting options:

1.     Submit PQRS quality measure data directly from their EHR system.  EPs who choose to report on EHR measures must report on a minimum of three measures for Medicare Part B beneficiaries at an 80 percent reporting rate to be able to qualify to earn a PQRS incentive payment.  Please refer to the relevant program year EHR Documents for EPs zip file for a list of measures available for reporting.  EPs participating in PQRS utilizing a qualified EHR Direct product should contact the qualified EHR Direct Vendor for additional details on submission.

2.     Submit PQRS quality measure data extracted from their EHR to a qualified EHR Data Submission Vendor. The EHR Data Submission Vendor would then submit the PQRS measures data to CMS in the CMS-specified format(s) on the EP’s behalf.  EPs who choose to report on EHR measures must report on a minimum of three measures for Medicare Part B beneficiaries at an 80 percent reporting rate to be able to qualify to earn a PQRS incentive payment.  Please refer to the relevant program year EHR Documents for EPs zip file for a list of measures available for reporting.  EPs participating in PQRS utilizing a qualified EHR Data Submission Vendor should contact the qualified EHR Data Submission Vendor for additional details on submission.

3.     Submit quality measure data through the PQRS-Medicare EHR Incentive Program Pilot which uses specific 2012 PQRS EHR measure specifications.  EPs participating in the Pilot are required to submit information on three core measures. If the denominator for one or more of the core measures is zero, the EP must report on up to three alternate core measures. EPs must also report on three additional measures available for the Medicare EHR Incentive Program. Please refer to the 2012 PQRS-Medicare EHR Incentive Pilot Quick-Reference Guide for a list of the core, alternate core and additional measures available for reporting.

 

More information & downloads available at cms.gov website.

PQRS - Important Dates


Prepare for Upcoming CMS Physician Quality Reporting System (PQRS) Program Milestones

Providers considered eligible and able to participate in the Centers for Medicare & Medicaid Services (CMS) Physician Quality Reporting System (PQRS) may be subject to a payment adjustment beginning in 2015. Eligible professionals (EPs) that do not report data on quality measures for covered professional services during the 2013 program year will be subject to a 1.5% payment adjustment beginning in 2015.

Below are important dates to guide successful participation in PQRS.

October 15, 2013


December 31, 2013


February 28, 2014

  • Milestones:
    • Last day to submit 2013 PQRS data through some reporting methods (deadline for submission of PQRS data varies by reporting method, but all methods require data to be submitted by end of first quarter in 2014)
    • Last day to submit CQMs for the PQRS-Medicare EHR Incentive Pilot Reporting Pilot Program
    • Last day that 2013 claims will be processed to be counted for PQRS reporting
  • Helpful Resources:

Wednesday, August 7, 2013

Omitting Federal Payers Doesn't Make Physicians 'Fraud-proof'

ARTICLE INFO:



Ericka L. Adler is a partner at the firm of Kamensky Rubinstein Hochman & Delott, LLP. Her primary practice focus is in the areas of regulatory and transactional healthcare law. Adler advises physicians and other providers regarding day-to-day practice management, physician contract matters, compliance and other business issues .



Date Posted: 07/31/2013
Written by: Ericka L. Adler

When setting up business arrangements with healthcare providers and entities, a common approach for physicians to take is to simply avoid including any federal business. This might mean agreeing to engage in a clinical study that doesn’t allow Medicare patients, or entering into lease arrangements for private paying patients only. There is a clear mindset among physicians, and very often those that represent them, that carving out federal program beneficiaries from an arrangement will immediately eliminate any concern associated with violating fraud and abuse laws.  Not only is this inaccurate, but it can often lead to violations of state laws that mimic federal regulations.  
      
Although the government has previously taken the position that excluding federal patients from business arrangements cannot guarantee compliance with federal law, the Office of Inspector General (OIG) has again made this position clear in recently issued OIG Advisory Opinion 13-03.In its opinion, the OIG reviewed a scenario where a clinical laboratory (“Parent Lab”) proposed to establish a management company to contract with physician groups to help them set up their own clinical laboratories. Under the proposed arrangement, each participating physician group would only refer non-federal healthcare patients to their on-site laboratory. Medicare and Medicaid patient specimens would be sent to the Parent Lab or another laboratory outside the medical practice. Sounds like a clean arrangement, doesn’t it? In its analysis of the facts, the OIG concluded that this arrangement could actually implicate or potentially violate the federal Anti-Kickback Statute because, in assisting a physician group to establish its own laboratory for non-federal business, the Parent Lab was likely inducing the physician practices to refer their federal healthcare business to the Parent Lab. In fact, the OIG presumed that obtaining the federal business was part of the actual intent of the Parent Lab from the start. The OIG argued in its analysis that physician groups that participated in such arrangements would be inclined to refer to the Parent Lab in an effort to secure more favorable contracts and pricing for the federal healthcare business referrals, and might feel obligated to send all of their federal healthcare patient specimens to the Parent Lab, even if medically unnecessary.Physicians involved in an arrangement (or considering one) where federal business is carved out, need to consider whether the arrangement really eliminates any need to consider the Anti-Kickback Statute or other federal healthcare laws. Additionally, there is often a focus on federal patients even when the arrangement would still violate state laws. With this in mind, I recommend physicians consider the following:1. Does your arrangement expressly carve-out federal program beneficiaries? If it does carve out federal patients, will referral of federal patients still be made to another party involved (directly or indirectly) in the arrangement? Is better pricing offered to the federal patients as compared to private patients? What is the true motive for entering into the relationship?2. If you think the arrangement does not involve any type of remuneration, are you certain? In the OIG opinion, it was determined that the Parent Lab was offering physician groups remuneration in the form of “business opportunity,” meaning physician groups essentially would have a laboratory “handed” to them and all they would have to do is move in and begin operations. Accordingly, it is important to remember that remuneration exists in many different forms and does not always involve outright payment for referrals. If the arrangement has the potential to reward a provider by offering an opportunity for increased referrals or profit, then it may implicate the Anti-Kickback Statute even if unrelated to federal healthcare patients. In light of the OIG opinion and the ever-expanding reach of healthcare regulations, physicians are well-advised to think critically about any type of arrangement that isolates payment and referrals for federal healthcare payers and programs.As always, it is important to consult with knowledgeable legal counsel who can assist you in detecting such unforeseen legal consequences, before the regulators start asking questions