HRSA’s Response on The Establishment of the CHGME Quality Bonus System
July 2, 2018:
Before we lose the interest of the non-children’s teaching hospitals, we would like to note, it may be wise to keep any changes in the CHGME funding in your sights; if successful, we do not see a reason why the Medicare GME Program couldn’t follow suit.
In the June 26, 2018 Federal Register 1, the Health Resources and Services Administration (HRSA) issued a final response to its request for feedback on the establishment of the Children’s Hospitals Graduate Medical Education Payment (CHGME) Program’s Quality Bonus System (QBS) for Fiscal Year (FY) 2019 and beyond. The CHGME Support Reauthorization Act of 2013 amended the CHGME statute to permit the additional payment to newly qualified hospitals and establish a QBS with any remaining funds. It is now estimated that there may be approximately $3 million available annually for the CHGME QBS.
We have highlighted some of the responses HRSA provided in the June 26th notice:
QBS Goals:
In the request for comment, HRSA proposed a multi-step implementation of the system beginning in FY 2019 that “will initially recognize high-level engagement of CHGME hospitals in state and regional health care transformation, as well as engagement of resident trainees in these activities.”2 After reviewing the comments received, HRSA has revised the goal of the QBS to be one that will “recognize hospitals for quality improvement & GME transformation efforts in high priority focus areas and build standards to increase engagement and involvement of residents in broader initiatives 1.”
Qualifying Initiatives for the FY 2019 QBS:
HRSA has decided that “in order to qualify for the FY 2019 QBS payment, CHGME awardees must submit documentation in the FY 2019 reconciliation application describing the hospital’s initiatives, resident curriculum, and direct resident involvement in the following areas: integrated care models, telehealth/HIT, population health, social determinants of health, and additional initiatives to improve access and quality of care to rural/underserved communities 1.”
Measures and Metrics:
HRSA will implement a baseline phase for CHGME QBS in FY 2019. The findings from this baseline will then be used to establish QBS standards for implementation in FY 2021. Some of the measures HRSA and the commenters have identified are outlined below:
- Documentation confirming participation in state- or regional-level pediatric health care transformation, including a description of how CHGME trainees are integrated into such transformation activities
- Percentage of residents’ training time and outcome of graduates participating in rural and underserved location
- Clinical Learning Environment Outcomes, including documenting the number of unnecessary medical tests, treatments, procedures, and hospital readmission rates
- Health Care Transformation Activities exhibited by the number of publications by resident and faculty.
Payment Structure
The FY 2019 CHGME QBS payment will be based on tiers, not reflective of the quality of the initiatives, but dependent on the size of the training programs and payments typically received per established payment formulas. Qualifying CHGME QBS awardees will be evenly divided into three tiers:
Tier 1 are hospitals that are in the lowest third among hospitals that qualify for the CHGME QBS and will receive a base payment.
Tier 2 are hospitals that are in the middle third; these hospitals will receive two times the base payment.
Tier 3 are hospitals that are in the highest third and will receive three times the base payment.
The base payment rate is determined from the total amount available and the number of qualifying hospitals for the CHGME QBS in a fiscal year.
Documentation, Reporting Requirements and Reducing Reporting Burden
HRSA promises to review current measures children’s hospitals are required to report that could be used for the QBS purposes and create reasonable requirements in order to minimize administrative burden for participants in this program.
In conclusion, we are looking forward to reviewing additional details and HRSA’s final guidance for the FY 2019 CHGME QBS in the future publication of the FY 2019 CHGME Notice of Funding Opportunity (NOFO).
¹ 83 Fed. Reg. 123 (June 26, 2018) pages 29796-29798
² 82 Fed. Reg. 198 (October 16, 2017) pages 48102-48103
About the Author:
Susan Fujioka
Senior Manager