CDC/ASPR Listening Session on Proposed Update to CMS CoP on Pandemic Reporting
5/17/22 — The CDC and the HHS Office of the Assistant Secretary for Preparedness and Response (ASPR) are holding virtual listening sessions on the proposed revision to hospital and critical access hospital Conditions of Participation (CoP) on hospital data reporting provisions for COVID-19 after the conclusion of the current public health emergency (PHE), as well as future PHE declarations related to acute respiratory illnesses. The proposed revision is included in the CMS FY 2023 Inpatient Prospective Payment System (IPPS) proposed rule and can be found on page 511 (Fed. Reg. 28618, bottom of the 3rd column) on this link.
You are invited to provide your feedback on the proposed policy and help inform CMS’s approach to these proposed hospital data reporting requirements. Prior to the listening session, you are encouraged to review the proposed rule and be prepared to speak to the following topic areas during the call:
1) If the COVID-19 Public Health Emergency were to expire, the reporting requirements proposed in the rule would be triggered with potential reporting until April 30, 2024. How could CMS mitigate challenges and unintended consequences? What efforts can CMS take to support transition from the existing COVID-19 reporting requirements to the continued COVID-19 reporting requirements proposed in the rule?
2) The regulation proposes to allow for the flexibility to reduce or limit the scope and frequency of the data reporting required based on the state of the PHE and ongoing circumstances. What is the current burden and financial impacts associated with COVID-19 reporting?
- How will this burden increase or decrease if the COVID-19 PHE were to expire and the proposed requirements for continued COVID-19 reporting were implemented?
- For future PHE declarations, what type of financial considerations are necessary to ensure readiness and compliance in the event data reporting is required as proposed?
- How significant are the variations in burden impacts based on the public health response to one specific pathogen or infectious disease versus another that would be directly related to a declared PHE? Are there different burden considerations when the PHE declaration is local, regional, or national?
3) How could CMS best align and incentivize preparedness, while also reducing burden and costs on regulated entities, and ensuring flexibility to quickly be informed and respond during emergencies?
4) What is an appropriate timeline and notification process to ensure that facilities are well aware in advance of CMS’s intention to collect such information for both continued COVID-19 reporting and reporting in the event of a future PHE declaration?
The listening session for public health and emergency response agencies is on May 24. Click here to register for this session.
The listening session for hospitals and health systems is on May 25. Click here to register for this session.
As always, APIC will be providing written comments to the CMS IPPS proposed rule on behalf of IPs.