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Starting next month, hospitals will be required by CMS to report their overall bed capacity as well as their census of patients with respiratory illnesses, including COVID-19 -- a requirement hospitals say will be more of a burden than a help.

"Hospitals and health systems understand the potential value of selected data on acute respiratory illnesses to inform public health efforts," Akin Demehin, senior director of quality & patient safety at the American Hospital Association, said in an email to MedPage Today. However, we continue to believe a Condition of Participation (CoP) to compel hospital reporting is needlessly heavy-handed and inconsistent with the core intent of CoPs."

"That is why we have advocated that CMS, CDC, and other federal agencies pursue a more collaborative approach that builds the infrastructure to make the sharing of infectious disease data less burdensome and more meaningful," Demehin said. "In the short term, we will continue to engage with CMS and CDC to ensure that hospitals have timely and complete information on how to meet these new requirements, and to ensure that their compliance is assessed fairly and accurately."

Data to Be Used for Infection Control Policies

The new requirement was as part of a 1,061-page rule covering changes to Medicare, Medicaid, the Children's Health Insurance Program, the Hospital Inpatient Prospective Payment System for acute care and long-term care hospitals, and other policies. The rule says hospitals "must electronically report data related to COVID-19, influenza, and RSV [respiratory syncytial virus] including confirmed infections of respiratory illnesses among hospitalized patients, hospital bed census and capacity (both overall and by hospital setting and population group [adult or pediatric]), and limited patient demographic information, including age. Beginning November 1, 2024, hospitals and CAHs [critical access hospitals] must electronically report this information to CDC's National Healthcare Safety Network or other CDC-owned or CDC-supported system, as determined by the [HHS] Secretary."

"Hospital and CAH-reported data on COVID-19, influenza, and RSV infections among patients, as well as hospital bed capacity and occupancy rates, continue to play a critical role in infection prevention and control efforts at every level of the health system," the authors of the rule wrote. "Comprehensive and consistent surveillance across hospitals creates a shared resource that all healthcare facilities in a community could use to inform infection control policies ... Not maintaining this reporting would result in an absence of vital information on local, regional, and national transmission and impact of respiratory illness and overall healthcare system capacity, with significant implications for both patient care and public health mitigation."

Like the American Hospital Association, the Federation of American Hospitals (FAH), a trade group for for-profit hospitals, also expressed opposition to the new rule. "The FAH does not support the proposed CoP and urges CMS to consider alternative approaches, such as voluntary reporting and investment in infrastructure for efficient data sharing," Charles N. "Chip" Kahn III, the federation's CEO, about a month after the proposed rule was issued in May. "We also recommend modifications to the proposed CoP if it is adopted, including allowing for weekly data snapshots, providing more specific data requirements, and removing the provision for increased reporting during potential [public health emergencies]."

Furthermore, an FAH spokesperson wrote to MedPage Today, "FAH has asked CMS to delay enforcement of the rule, issue more clear guidance, and exclude IRF [inpatient rehabilitation facility] and IPF [inpatient psychiatric facility] hospitals; the final rule requirement is significantly more burdensome than the data reporting requirements for IRF and IPF hospitals during the public health emergency."

Support From Patients

In the final rule, CMS noted that it "received overwhelming support from patients and community members on our proposal to extend requirements for respiratory illness reporting in the hospital and CAH CoPs. Many commenters expressed that such data, when reported publicly, helps to inform both public and personal healthcare decisions. We received some anecdotes on personal experiences with long COVID as well as stories of loved ones who died due to COVID."

This new rule -- which requires weekly reporting of most data elements -- is overall less burdensome than compared to earlier capacity reporting requirements, which mandated daily reporting, Harold Miller, president and CEO of the Center for Healthcare Quality and Payment Reform, in Pittsburgh, said in an email. "However, [that] doesn't mean it isn't burdensome, particularly for a small facility."

He noted that CMS estimates 39 hours of work per year per hospital by a nurse to do the reporting, "which is equivalent to a week of time that can't be used for patient care or other activities. A facility isn't going to be able to hire an additional nurse to do a task that requires a week of time, so the existing staff will have to do the work, and that will reduce the amount of time they have for other activities."

This new rule is one of many unfunded mandates in the Medicare CoPs, and although each individual mandate may be a worthy one, "if there is no payment to support it, it increases costs without correspondingly increasing revenues," Miller wrote. "Each individual mandate may have a small impact, but many mandates with small impacts can add up to a high total cost, and without accompanying revenue, that means a high total loss ... At a small hospital that is already losing money, it increases the overall losses and makes it more likely that the hospital will be forced to close."

The government should be funding any mandates it imposes, he added. "If a mandate is important, then it should be paid for. It's not enough for CMS to simply estimate the cost of implementing a new mandate -- it needs to address the issue of how that cost will be paid for. Moreover, in this case, the thing that is being mandated is desirable, but it does not do anything directly to improve care of the patients who are in the hospital ... An activity designed to support public health data needs to be paid for directly in order to ensure that there are adequate resources to do it properly."

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