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December 2, 2024
2025 OPPS Final Rule: Quality Reporting Provisions

2025 OPPS Final Rule: Quality Reporting Provisions

Our final article relating to the 2025 Outpatient Prospective Payment System (OPPS) final rule will focus on the quality reporting requirements for next year. The following highlights can be found in a fact sheet on the final rule published by the Centers for Medicare and Medicaid Services (CMS).

2025 OPPS Final Rule: Quality Reporting Provisions

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Hospital Inpatient Quality Reporting (IQR) Program 

The Hospital IQR Program is a pay-for-reporting quality program that reduces payments to hospitals that do not meet program requirements. Hospitals that do not submit quality data or do not meet all Hospital IQR Program requirements are subject to a one-fourth reduction in their Annual Payment Update under the Inpatient Prospective Payment System. 

In the 2025 OPPS final rule, CMS is finalizing its proposal to continue voluntary reporting of the core clinical data elements (CCDEs) and linking variables for both the Hybrid Hospital-Wide Readmission and Hybrid Hospital-Wide Standardized Mortality measures, for the performance period of July 1, 2023, through June 30, 2024, impacting the FY 2026 payment determination for the Hospital IQR Program. CMS is also extending the voluntary reporting of the CCDEs and linking variables for the July 1, 2024 through June 30, 2025 performance period, which is associated with the FY 2027 payment determination.

Hospital Outpatient Quality Reporting (OQR) Program

The Hospital OQR Program is a pay-for-reporting quality program for hospital outpatient departments. Hospitals that fail to meet the OQR reporting requirements will receive a reduction of two percentage points to their Annual Payment Update under the OPPS.

The final rule adopts the following measures: (1) the Hospital Commitment to Health Equity measure beginning with the CY 2025 reporting period/CY 2027 payment determination; (2) the Screening for Social Drivers of Health measure beginning with voluntary reporting in the CY 2025 reporting period, followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination; (3) the Screen Positive Rate for Social Drivers of Health measure beginning with voluntary reporting in the CY 2025 reporting period, followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination; and (4) the Patient Understanding of Key Information Related to Recovery After a Facility-Based Outpatient Procedure or Surgery, Patient Reported Outcome-Based Performance measure beginning with voluntary reporting in the CY 2026 reporting period, followed by mandatory reporting beginning with the CY 2027 reporting period/CY 2029 payment determination.

In addition, the final rule removes the following measures: (1) the MRI Lumbar Spine for Low Back Pain measure beginning with the CY 2025 reporting period/CY 2027 payment determination and (2) the Cardiac Imaging for Preoperative Risk Assessment for Non-Cardiac, Low-Risk Surgery measure beginning with the CY 2025 reporting period/CY 2027 payment determination. 

CMS is also finalizing proposals to: (1) modify the immediate measure removal policy to an immediate measure suspension policy for adopted Hospital OQR Program measures; (2) require that electronic health record (EHR) technology be certified to all electronic clinical quality measures available to report in the Hospital OQR Program; and (3) publicly report the Median Time from Emergency Department (ED) Arrival to ED Departure for Discharged ED Patients measure-Psychiatric/Mental Health Patients strata on the Compare tool hosted by HHS, available at: https://www.medicare.gov/care-compare/.

Rural Emergency Hospital Quality Reporting (REHQR) Program

A rural emergency hospital (REH) is a facility that, in relevant part as of December 27, 2020, was a critical access hospital (CAH) or a subsection (d) hospital with not more than 50 beds located in a county (or equivalent unit of local government) that is in a rural area (defined at section 1886(d)(2)(D) of the Act), or was a subsection (d) hospital with not more than 50 beds that was treated as being in a rural area (pursuant to section 1886(d)(8)(E) of the Act). An REH must submit quality measure data to the Secretary, and the Secretary shall establish procedures to make the data available to the public on a CMS website.

The 2025 OPPS final rule adopts the following: (1) the Hospital Commitment to Health Equity measure beginning with the CY 2025 reporting period/CY 2027 program determination; (2) the Screening for Social Drivers of Health measure beginning with voluntary reporting in the CY 2025 reporting period, followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 program determination; and (3) the Screen Positive Rate for Social Drivers of Health measure beginning with voluntary reporting in the CY 2025 reporting period, followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 program determination. 

CMS is also finalizing its proposals to: (1) extend the reporting period for the Risk-Standardized Hospital Visits Within 7 Days After Hospital Outpatient Surgery measure from one year to two years beginning with the CY 2025 reporting period; and (2) establish when, after conversion to REH status, REHs would be required to report data under the REHQR Program, such that an REH would begin submitting data to the REHQR Program on the first day of the quarter following the date that a hospital has been designated as converted to an REH.

More details concerning the 2025 OPPS final rule can be found by clicking on the following link: CY 2025 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Final Rule (CMS 1809-FC) | CMS