In its Proposed Rule released on Wednesday, July 6, 2016, the Centers for Medicare and Medicaid Services (CMS) announced their intention to suspend the inclusion of a Pain Management dimension in the calculation for the HCAHPS domain of VBP. A few quotes from that Federal Register notice:
- Some stakeholders believe that the linkage of the Pain Management dimension questions to the Hospital VBP Program payment incentives creates pressure on hospital staff to prescribe more opioids in order to achieve higher scores on this dimension.
- We continue to believe that pain control is an appropriate part of routine patient care that hospitals should manage and is an important concern for patients, their families, and their caregivers.
- Although we are not aware of any scientific studies that support an association between scores on the Pain Management dimension questions and opioid prescribing practices, we are developing alternative questions for the Pain Management dimension in order to remove any potential ambiguity in the HCAHPS Survey.
The proposal is to remove the Pain Management dimension effective for the FFY 2018 payment year, which uses the 2016 calendar year as its performance period. In other words, this change would be effective NOW and would impact the VBP estimates you are looking at currently.
As with all Proposed Rules, CMS is inviting public comment, and I imagine they will receive MANY comments for and against this proposal. On July 14, 2016, the official Federal Register version will be available here. Also on this page, you will find a link that allows you to submit a comment regarding any of the proposals in the document. We expect the Final Rule based on this proposal to be available in mid-November.
To be clear, CMS is NOT proposing at this time to remove the questions from the HCAHPS survey; the existing Pain Management questions will continue to be asked of all patients. When CMS has completed their research into alternative questions to assess pain management, these questions will be removed, and new questions will be added. CMS employs a rigorous research and testing protocol for new measure development, and we think it is likely 18 months to two years away from being finalized; CMS has not provided a timeline.
We will continue to monitor this conversation and provide updates as they become available.
Written by Jan Gnida, Director, Patient Experience & Government Surveys