On May 10th, 2022, the Centers for Medicare and Medicaid Services (CMS) released its annual update to the Hospital Inpatient Prospective Payment System (IPPS). In addition to payment updates, the rulemaking includes proposed measures to improve health equity and maternal health outcomes. This includes establishing a “maternal morbidity structural measure,” new quality measures, and a request for comment on additional ways the agency can improve its program requirements to advance maternal health equity.[i]
Maternal Morbidity Structural Measure and “Birthing Friendly” Designation
To help consumers find hospitals with high quality maternal health care, CMS is proposing the creation of a “Birthing Friendly” hospital designation, to become available in the fall of 2023. To receive the designation, hospitals must report “yes” to the Maternal Morbidity Structural Measure available as part of the Hospital Inpatient Quality Reporting Program.[ii] By reporting “yes” to the structural measure, hospitals are agreeing to participate in a state or national Perinatal Quality Improvement Collaborative and implement safety practices or bundles as recommended by this Perinatal Quality Improvement Collaborative.[iii]
Perinatal quality collaboratives are networks of teams comprised of public health and hospital leaders that work together to improve maternal health care delivery.[iv] They do so by identifying common state-level maternal health problems, creating a project targeted at improving the problem, recruiting hospitals to participate, collecting data, and sharing results with the participating hospitals to promote collaborative learning.[v] Maternal safety bundles are evidence-based strategy frameworks developed by these perinatal quality collaboratives that health care institutions and their clinicians can implement to improve maternal health outcomes. For example, the perinatal quality collaborative, “the Alliance for Innovation on Maternal Health” (AIM) has a four-step framework to improve hospital responses to instances of patient hemorrhaging during birth or pregnancy.[vi]
New Quality Measures
In addition to the maternal morbidity structural measure, CMS is also adding two additional quality measures to the Hospital Inpatient Quality Reporting System to improve maternal health. First, a cesarean section (C-section) birth quality measure aims to address the higher rate of maternal mortality and morbidity for C-sections compared to traditional birth.[vii] It does so by having hospitals report their rates of non-medically necessary C-sections, which can then be compared to other hospitals.[viii] Second, a severe obstetric complications quality measure aims to impact the United States’ high rates of pregnancy-related deaths and serious medical complications. The measure assesses the proportion of patients that develop a severe obstetric complication which was not present upon hospital admittance, adjusting for risk factors such as age or preexisting conditions.[ix] Both of these new quality measures are optional for hospitals to self-select in calendar year 2023 and are proposed to become mandatory in calendar year 2024 forward.[x]
Request for Comment
CMS is requesting comments on these proposed measures and other ways in which the Department can facilitate improved maternal health care delivery. The deadline to submit comments is June 17th, 2022. A review of comments received thus far indicate general support for these additional measures. Of relevance, commenters emphasized that in addition to these system-level changes, CMS should prioritize educating practitioners on the ways implicit bias and racism can impact health care delivery. One commenter also mentioned the importance of, and often lack of, resources related to maternal mental health, and recommended increased provider education on this topic. On a more technical note, some commenters suggested that the Perinatal Quality Improvement Collaborative and the maternal safety bundles referred to in the Maternal Morbidity Structural Measure should each be split into separate measurements. Others indicated that the Maternal Morbidity Structural Measure should include an adjustment for rural hospitals that accounts for additional difficulty they may have in participating.
For further information on this rulemaking, see the CMS Fact Sheet on the 2023 IPPS changes and maternal health and the full proposed rule available on the Federal Register.
[i] FY 2023 Hospital Inpatient Prospective Payment System (IPPS) and Long Term Care Hospitals (LTCH PPS) Proposed Rule – CMS-1771-P (Maternal Health) | CMS
[ii] Id.
[iii] Id.
[iv] Perinatal Quality Collaboratives | Perinatal | Reproductive Health | CDC
[v] Id.
[vi] QSO-22-05-Hospitals (cms.gov)
[vii] Federal Register :: Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2023 Rates; Quality Programs and Medicare Promoting Interoperability Program Requirements for Eligible Hospitals and Critical Access Hospitals; Costs Incurred for Qualified and Non-Qualified Deferred Compensation Plans; and Changes to Hospital and Critical Access Hospital Conditions of Participation
[viii] Id.
[ix] Id.
[x] Id.