U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
CENTERS FOR MEDICARE & MEDICAID SERVICES
OFFICE OF MANAGEMENT AND BUDGET
PAPERWORK REDUCTION ACT
CLEARANCE PACKAGE
SUPPORTING STATEMENT-PART A
ACA §3004 LTCH Quality Reporting Program:
Program Evaluation
Supporting Statement for Paperwork Reduction Act Submissions
Part A
ACA §3004 LTCH Quality Reporting Program:
Program Evaluation
Section 3004(a) of the Patient Protection and Affordable Care Act (ACA) mandated that the Centers for Medicare & Medicaid Services (CMS) establish a quality reporting program for Long Term Care Hospitals (LTCHs). Specifically, section 3004(a) added section 1886(m)(5) to the Social Security Act (the Act) to establish a quality reporting program for LTCHs. This program requires that quality data be submitted by LTCH providers in a time, form and manner specified by the Secretary.
Beginning in FY 2014, section 1886(m)(5)(A)(i) of the Act requires the reduction of the annual update to the standard Federal rate, by 2 percentage points for any LTCH that fails to submit data to the Secretary in accordance with requirements established by the Secretary for that fiscal year.
The Centers for Medicare & Medicaid Services has established quality reporting and public reporting programs for various care settings with the goal of promoting higher quality and more efficient healthcare for Medicare beneficiaries. These programs have helped focus quality improvement efforts and provide stakeholders information needed for decision-making. The overall goal for CMS is to achieve the Department of Health and Human Services’ (HHS) aims as outlined in the National Quality Strategy: Better Care, Healthy People/Healthy Communities and Affordable Care.
The following are examples of some of the healthcare services that are measured through the CMS quality measurement programs: (1) hospital inpatient services are monitored through the Hospital Inpatient Quality Reporting (IQR) Program; (2) hospital outpatient services are monitored with the Hospital Outpatient Quality Reporting Program (OQR); and, (3) the quality of services rendered by physicians and other eligible professionals’ services are monitored with the Physician Quality Reporting System (PQRS). In addition, CMS has implemented quality reporting programs for home health agencies and nursing facilities.
Section 3004(a) of the Affordable Care Act (ACA) established the Long Term Care Hospital Quality Reporting (LTCHQR) Program. This program requires data related to quality measures to be submitted to CMS in a time, form and manner as specified by the Secretary. Eventually, as statutorily required, CMS will publicly report the data once those providers have had the opportunity to review that data before it is made public.
CMS has experience in implementing, monitoring, and evaluating quality reporting programs (QRPs). Such activities have been established for the inpatient and outpatient settings. In addition to LTCHs, ACA Section 3004 also established quality reporting programs for inpatient rehabilitation facilities and hospices. CMS is interested in exploring how LTCH providers are responding to the new QRP and its measures. We believe that it is important to understand early trends in outcomes, to make adjustments as needed to enhance the effectiveness of the program, and to seek opportunities to minimize provider burden, and ensure the quality reporting program is useful and meaningful to the providers.
In order to implement and execute a valid and meaningful QRP program, it is essential that the data collected not only be accurate, but that CMS is able to evaluate the success of the program to determine if it is meeting its stated goals. Therefore, we believe that ongoing programmatic evaluation such as the monitoring of its processes, requirements, and impact is both fundamental and essential for evaluating overall programmatic impact. In this, we believe it is important for CMS to be informed about providers’ experiences related to the program.
We believe that the data collection from the LTCHQR Program’s program evaluation activities will help inform CMS in next steps related to Monitoring and Evaluation-related activities; particularly with monitoring. It is essential to perform monitoring and evaluation (M&E) activities over the life of a program to understand how well the program is meeting its intended goals and to discover any need for program improvement. Monitoring (formative evaluation) is an “early warning” system for alerting CMS of both anticipated and unanticipated interim trends and patterns related to program implementation and performance in near to real time. Goals related to monitoring efforts include:
Enabling early intervention if any changes to the program are necessary
Determining if those implementing the program require technical assistance
Providing stakeholders with information on early achievements
Monitoring activities are implemented at the start of a program to track the positive, negative, or unanticipated effects of the program in real time. The LTCHQR Program’s program evaluation activities would serve these early steps. Such first steps enable the building of trust between CMS and its stakeholders who can serve to inform CMS in its decision making about any needed changes in the QRP, as well to identify how to best meet the needs of providers in anticipation of how they will use the information gleamed from monitoring and evaluation-related activities. This survey/interview would allow for direct feedback from providers to obtain their perspective and build upon that partnership for more formal dialogue in the future, as the QRP matures. Therefore, the purpose of evaluating the LTCHQR Program is multi-fold, including: determining how providers are responding to the new QRP, the mechanisms utilized by providers to collect and report data (inclusive of determining the accuracy of that data), burden, practices related to data collection, use of EHRs, etc., and the overall impact and influences of the QRP on healthcare outcomes. We believe that program evaluation is a learning opportunity for the providers and for CMS.
The methodology employed in the evaluation is the utilization of qualitative interviews (as opposed to quantitative statistical methods). In consultation with research experts, CMS has decided that at this juncture it would be meaningful to use a rich, contextual approach to evaluate the process and success of the QRP initiative. A qualitative approach uses a semi-structured interview methodology (i.e., wording and order of questions is not expected to be precisely the same for all providers). The goal of a qualitative interview process is to elicit information from participants while minimizing response bias, and allowing the subject to lead the discussion. Outlined in this PRA are nine (9) discussion topics (listed as questions), with probable follow-up topics, but each discussion is likely to take on its own characteristic. The decision to pursue this methodology (i.e., qualitative) was informed by our earlier pilot discussions with a small number of providers (i.e., less than nine) in 2013, in which we learned that providers are anxious to have their voice heard, but that they did not feel comfortable expressing themselves fully in public open door forums. Providers desired some level of confidentiality, which this methodology affords.
To perform this program evaluation activity, CMS will be seeking voluntary, provider input in this program evaluation. CMS, in collaboration with its contractor will be reviewing the input from providers to help direct the future actions of the QRP. Voluntary participation in this phase of the evaluation of the new QRP can be beneficial to the provider facilities by lending them a voice in how the QRP continues in its implementation. Participation by the LTCH is fully voluntary with no risk of penalty if the decision is made to not participate.
Data Submitters –LTCHs (participation is on a voluntary basis)
Data Users:
CMS – CCSQ / QMHAG / Division of Chronic & Post-Acute Care (DCPAC)
The intended use of the information collected is to help inform CMS providers’ experiences related to the QRPs, such as program impact related to quality improvement, burden, process-related issues, and education. This will also inform future measurement development for the LTCH QRP, future steps related to data validation, as well as future monitoring and evaluation. General findings may be used to discuss CMS’ future efforts in the QRP.
Health Care Innovation Services (HCIS) –CMS’ data analysis contractor will obtain the data on behalf of CMS and will perform the above-described program evaluation activities with the information that is obtained.
The information to be collected as part of the LTCHQR Program’s ongoing evaluation activities, and will be collected using a personal interview technique (either in person or via telephone). LTCH providers will not be asked to provide any information to CMS using any type of information technology.
This information collection does not duplicate any other effort.
Participation in the evaluation activities of the LTCHQR Program will have little, if any, effect on LTCHs that are considered to be small businesses because provider participation during this phase is completely voluntary and there will be no penalty placed on an LTCH for non-participation.
Program evaluation will involve using a qualitative structured interview process to learn from providers how the QRP has impacted their service delivery; how they capture, record, and validate data; and any barriers or obstacles to data accuracy. Qualitative data involves analysis for thematic patterns and does not include statistical analysis that is associated with quantitative data methods.
The 60-day Federal Register notice published on March 10, 2014. There were no comments received.
There will be no payments/gifts to LTCHs for participation. There are no penalties for non-participation.
No patient level data will be collected as part of this process. All participants will be notified that everything they say will be confidential. Data will be treated in a confidential manner, unless otherwise compelled by law.
No personal health information (PHI) will be collected as part of the process. Interview subjects will be informed that they can choose to not answer any question(s) that they feel uncomfortable answering.
Time Burden Calculation
Number of LTCHs to participate in evaluation process: 30
Data collection method to be used: In-person or telephone interviews
Number of staff at each LTCH location to be interviewed: 2
Job titles of LTCH staff to be Interviewed:
Nursing Administrator (i.e. - Director of Nursing / Nurse Manager of LTCH Unit)
Infection Control/Quality Assurance Coordinator (Registered Nurse)
Number of questions to be used in interview = 9
Estimated average time required to complete each interview question = 7 minutes
Estimated Time Required to Complete Interviews of 2 LTCH staff = 126 minutes
9 questions per interview x 7 minutes per question = 63 minutes (Nurse Administrator)
9 questions per interview x 7 minutes per question = 63 minutes (IC/QAC Nurse)
126 minutes / 60 minutes per hour = 2.1 hours
Other Estimated Burden Associated with LTCH Monitoring Program = 15 minutes
Estimated time spent by LTCH to arrange for participation in Program = 15 minutes
(i.e. – prepare for CMS arrival at facility, Introductions to staff, explanations of interview, preparations, time between interviews, etc.)
126 minutes - Interviews of 2 LTCH nurses
15 minutes - Time spent by facility to arrange for participation in program
141 minutes – Total estimated time per each LTCH
141 minutes/60 minutes per hour = 2.35 hours
2.35 hours per each LTCH x 30 LTCHs = 71 hours across 30 LTCHs to be interviewed
Wage Calculation
We estimate that the following tasks will be performed by the Nurse Administrator:
Estimated average time for interview by CMS representative 63 minutes
Total 63 minutes
We estimate that the following task will be performed by the IC/QAC Nurse:
Estimated average time for preparation interview by CMS representative 78 minutes
According to Salary.com and the U.S. Bureau of Labor Statistic, the average hourly wages for the nurses that CMS plans to interview are as follows:
Job Title Avg. Hourly Estimated Yearly
Wage Wage
Nurse Administrator $40.52 $84,282 per year1
Infection Control/ ` $34.78 $72,351 per year2
Quality Assurance Coordinator Nurse
Nurse Administrator Wages:
a. Wages per Each LTCH:
63 minutes / 60 minutes per hour = 1.05 hours
1.05 hrs. x $40.52 per hour = $42.553
b. Across all 30 LTCHs
1.05 hours x 30 LTCH = 31.5 hours
31.5 hours x $40.52 per hour = $1,276.38
Infection Control/Quality Assurance Coordinator Nurse Wages:
Wages Per Each LTCH:
78 minutes / 60 minutes per hour = 1.3 hours
1.3 hours x $34.78 per hour = $45.214
b. Across all 30 LTCHs:
1.3 hours x 30 LTCH = 39 hours
39 hours x $34.78 per hour = $1,356.42
Total Estimated Wages to be Incurred By Each LTCH For Program Evaluation Activities:
$ 42.555 Nurse Administrator Wages
$ 45.216 Infection Control/Quality Assurance Nurse Wages
$87.76 TOTAL
Total Estimated Wages to be incurred across 30 Participating LTCHs for Program Evaluation Activities:
$1,276.38 Nurse Administrator Wages
$1,356.42 Infection Control/Quality Assurance Nurse Wages
$2,632.80 TOTAL
There are no capital costs.
CMS will use their data analysis contractor, HCIS to assist them with the administration of the LTCHQR Program: Program Evaluation. CMS will incur costs associated with the work performed by this contractor. The estimated annual cost to the government for the work to be performed by HCIS is estimated to be $125,000.
The work to be performed by HCIS for LTCH QRP Program Evaluation includes the following annual tasks: (1) to give notice and educational information to LTCHs about the new LTCHQR Program: Program Evaluation; (2) to invite LTCHs to voluntarily participate in the program; (3) to select 30 LTCHs for participation in the LTCH QRP Program Evaluation; (4) to perform interviews with two nurses at each selected LTCH; (5) to compile and analyze all data obtained from the staff interviews at each selected LTCH; (6) to provide CMS with a report which summarizes the data obtained, then states findings, conclusions, and recommendations.
This is a new data collection.
16. Publication/Tabulation Dates
CMS may use the data collected to inform the LTCHQR Program as it develops however, at this time the data is not intended for public display. In the future CMS may find that the publication of general findings are informative and useful for public benefit.
Not applicable because no written materials will be disseminated to providers.
3 This number is rounded to the nearest cent (i.e., $42.546).
4 This number is rounded to the nearest cent (i.e., $45.214)
5 This number is rounded to the nearest cent (i.e., $42.546).
6 This number is rounded to the nearest cent (i.e., $45.214)
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2021-01-27 |