2022 Quality Measures for Anesthesia

The 2022 FR provides details on how the Merit-based Incentive Payment System (MIPS), MIPS Value Pathways (MVPs), Alternative Payment Models (APMs) and other features of the Quality Payment Program (QPP) will operate during the 2022 performance year and beyond.

According to the ASA, CMS finalized the anesthesiology MVP for the 2023 reporting year.  In 2022, QPP participants will see some modifications to the program, including:

  • The MIPS performance threshold will be set at 75 points with an exceptional performance bonus applied to those individuals and groups scoring over 89 points. Individuals and groups receiving less than 75 points will incur a payment penalty on a sliding scale up to 9 percent in 2024, with those scoring under 18.75 points incurring an automatic -9 percent adjustment.
  • The quality and cost performance categories will be equally weighted at 30 percent of the total MIPS score.  Promoting interoperability and Improvement Activities performance categories will maintain their respective 25 percent and 15 percent weights, respectively.
  • The MIPS #44 measure (Coronary Artery Bypass Graft (CABG) – Preoperative Beta-Blocker in Patients with Isolated CABG Surgery) will be retired from the MIPS program.
  • The PSH Care Coordination improvement activity is now a “High” weighted improvement activity.  The ASA asserts that this designation will reduce group burden on reporting improvement activities by half.

Interestingly, CMS did not finalize its proposal to increase the completeness threshold to 80 percent in the MIPS Quality performance category in 2023 as previously proposed.  Instead, CMS will maintain a completeness of 70 percent for the next two years. ASA expects to update its Quality Payment Program website in the next few weeks with regulatory information and the Anesthesia Quality Institute expects to publish its 2022 QCDR measures book by mid-December as well. CMS expects to publish the 2022 MIPS measure specifications and other regulatory guidance within the next few weeks on the QPP website.

An Opportunity for Anesthesia to Lead

The severe shortage of sodium chloride 0.9% IV bags and other saline bags due in large part to the devastation wrought by Hurricane Maria on pharmaceutical plants in Puerto Rico offers one of the more unsettling recent examples.  (The commonwealth manufactures more pharmaceuticals for the United States than any of the 50 states or any foreign country.)

To help address the shortage, on January 24, the Food and Drug Administration (FDA) extended the shelf life of certain IV solutions made by Baxter Healthcare beyond the manufacturer’s labeled expiration date.  In a statement, the FDA said it expects the shortage will improve in the coming weeks and months and is working with manufacturers to import product into the U.S. from their foreign facilities.  (A comprehensive fact sheet on strategies for dealing with shortages of small-volume parenteral solutions is available from the ASHP.)

Drug shortages tend to hit anesthesia especially hard. In October 2017, the FDA announced a nationwide shortage of many injectable forms of fentanyl citrate, a shortage that persists.  A 2014 GAO study found that central nervous system drugs accounted for 17 percent of all drug shortages and that the shortages of these drugs were routine.  A 2012 survey by the American Society of Anesthesiologists (ASA) found that 97.6 percent of responding anesthesiologists were experiencing at least one anesthesia-related drug shortage. 

Anesthesia providers have used some innovative approaches to help prevent or reduce the impact of drug shortages in the past at their institutions.  Duke University Hospital (Durham, NC) formed a multidisciplinary perioperative drug shortage response team to address shortages of neuromuscular blocking agents such as succinylcholine in their operating rooms.

When a shortage is deemed critical, the coordinator of the Center for Medication Policy convenes a task force to discuss whether the shortage can be managed best by pharmacy alone or by a multidisciplinary group that includes anesthesiologists, nurse anesthetists, surgeons and OR nurses.

The team also uses data from its anesthesia information management system (AIMS) to identify trends and patterns in medication usage in the perioperative setting and develop strategies to repackage bulk medications into smaller unit doses whenever possible.  The approach allows the hospital to conserve inventory, reduce waste and extend the availability of difficult to obtain medications.

Anesthesia providers might also take a cue from pharmacist Trac Pham, RPh, of Advocate Health Care, who outlined strategies that have worked at his health system:

  • Use inventory control specialists whose responsibilities revolve around identifying red flags such as back orders and partial fulfillments. Empower frontline employees to identify these potential shortages.
  • Assess current inventory when a potential shortage has been identified—a step many hospitals fail to take. How much is sitting on the shelf today?  What is the hospital’s utilization rate?  How long is the current supply going to last?
  • Collaborate with supply chain and pharmacy to evaluate potential shortages, identify alternative therapies, prioritize patients who should receive the affected drug and modify clinical plans.
  • Develop a process that allows executives, clinicians and employees to communicate in a timely manner with each other to navigate drug shortages.
  • To ensure uninterrupted care, update the health information management system promptly to reflect alternative drugs when there is a shortage. 

For more information, also see the ASHP Guidelines on Managing Drug Product Shortages in Hospitals and Health Systems, American Journal of Health-System Pharmacy, 2009; 66:1399-405.