CMS Listening Session: Development of Additional Imaging Efficiency Measures for Use in the Hospital Outpatient Quality Data Reporting Program

March 22, 2011

CMS Listening Session: Development of Additional Imaging Efficiency Measures for Use in the Hospital Outpatient Quality Data Reporting Program

The purpose of the listening session was for CMS to solicit comments from stakeholders regarding the CMS approach to developing imaging efficiency measures for the Hospital Out Patient Quality Data Reporting Program (HOP QDRP).

The session was not designed to be in question and answer format; CMS will take comments and will not respond to questions during this session. 

Additional comments can be submitted electronically until 5pm ET on Thursday, February 10, 2011. A transcript of the session will be available online on the Quality Net website in approximately three weeks.

Welcome and Overview of Program:

Dr. Michael Rapp offered a brief history of the program noting that out of a sense of overuse of imaging procedures, the measures were developed to improve quality and not just reflect what physicians were ordering (quality vs. utilization).  By using claims data, there is minimal administrative burden for the hospitals.  Two sets of imaging efficiency measures are collected from HOPPS claims; using guidelines to establish measures which gage the acceptance of use by the profession.  There are vast differences in the use of some imaging procedures (e.g. use of contrast material in chest CT vs. abdominal CT; not sound consensus within the profession).  Moving forward, CMS would like to remove the constraint of collecting data through claims only and looking for to how EHRs can be used for data collection. 

Overview of Existing Measures:

A goal of the existing measures is to promote high quality of care by reducing exposure to agents and radiation.  CMS wants to avoid the use of resources that do not provide any benefit to the patient; classified as waste.  A 2009 RAND report defined clinical waste as when the cost of the service outweighs the benefit to the patient.  This can vary however, what is beneficial for one patient may not be for another.  CMS defines this as the absence of waste; this is not to limit access, but to ensure the right test is given to the right patient at the right time.  In the OPPS 2009 Final Rule, CMS began to publically report on the four measures through the Hospital Compare website (OP 8, 9, 10, 11).  In 2011, three additional measures were defined in the OPPS and will be implemented in CY2012.  Public reporting of the new measures (OP 13, 14, 15) will begin in the summer of 2012.  This will be through annual reporting, not quarterly.  The Out Patient Imaging Efficiency Measures program will be based on paid final claims, with no additional data collection from the hospital.

The goals of these measures are:

  1. Educate patients and increase awareness so a patient can make an educated decision about their care
  2. Understand potential health risks including exposure to unnecessary radiation and/or contrast materials and care not consistent with guidelines
  3. Promote hospitals assessing outpatient care for Medicare beneficiaries

CMS would like stakeholders to consider the following when making suggestions for the development of additional imaging efficiency measures:

  1. Importance – impact on health care
  2. Scientific soundness – science supporting the measure
  3. Usability – actionable information
  4. Feasibility – data is available and burden of data collection is minimized as much as possible

CMS recommended the following for discussion topics:

  1. Additional imaging procedures that would be appropriate candidates for imaging efficiency measures;
  2. Data sources and methods appropriate for imaging efficiency measures, e.g., claims data, chart abstracted data, EHRs, use of registries, etc.;
  3. Development of imaging measures using a diagnosis or condition based approach versus measures developed using a procedure specific basis;
  4. Other settings appropriate for imaging efficiency measures, in addition to outpatient hospitals;
  5. Recommendations/feedback on the integration of the imaging efficiency measures into the overall HOP QDRP program