In its FY 2023 Inpatient Prospective Payment System (IPPS) Proposed Rule, the Centers for Medicare & Medicaid Services (CMS) proposed including an electronic clinical quality measure (eCQM) developed and tested by Avalere Health, the Global Malnutrition Composite Score (GMCS), in the Hospital Inpatient Quality Reporting (IQR) Program. If included in the final rule, the GMCS would be the first composite eCQM and first nutrition-focused quality measure included in any CMS payment program.

The Hospital IQR Program is a voluntary program that promotes the reporting of inpatient quality-of-care measures. Hospitals that meet all program requirements receive the full Medicare Annual Payment Update (APU), which is the yearly increase in Medicare payment rates for inpatient services. Hospitals that elect not to participate or that do not meet requirements do not receive the full APU. If the proposal is finalized and the GMCS is included, hospitals participating in the Hospital IQR Program can elect to report the GMCS as one of their submitted eCQMs beginning in CY 2024. Stakeholders can submit comments on this measure’s inclusion and any other IPPS proposed rule changes to CMS until June 17, 2022. The CMS is expected to release the final rule in August, which will contain the finalized measure set.

New Composite eCQM Focused on Inpatient Malnutrition Care

The GMCS was developed by Avalere in partnership with the measure steward, the Academy of Nutrition and Dietetics, to measure quality malnutrition care delivered to patients age 65 and older in the inpatient setting. The National Quality Forum endorsed the measure in 2021. It is calculated as the average of the performance scores for 4 component eCQMs:

• Malnutrition screening of patients age 65 years and older
• Nutrition assessment of patients age 65 years and older at risk for malnutrition
• Appropriate malnutrition diagnosis documentation for patients age 65 years and older identified as malnourished
• Nutrition care plan documentation in the medical record for malnourished patients age 65 years and older identified as malnourished

The 4 individual eCQMs that compose the GMCS were developed as part of the Malnutrition Quality Improvement Initiative (MQii), a nationwide initiative facilitated by Avalere and led by the Academy and other partners to advance high-quality, evidence-based malnutrition care. The creation of the GMCS and its inclusion in the 2023 IPPS proposed rule is the result of more than 8 years of collaboration and effort by MQii stakeholders. In addition to quality measures, the MQii provides a free toolkit of web-based resources to support malnutrition quality improvement. Hospitals can participate in the MQii as a Learning Collaborative member and join the 313 existing sites across 38 states and Puerto Rico currently collaborating to improve care in their institutions and communities. Their efforts and successes have been documented and shared widely, such as in the 2019 supplement to the Journal of the Academy of Nutrition and Dietetics. Real-world data collected through these hospitals form 1 of the largest nutrition care datasets of its kind, now including more than 1.5 million hospital encounters.

Benefit to Hospitals of Implementing the Global Malnutrition Composite Score

Malnutrition is a burdensome condition estimated to affect more than 30% of hospitalized adults but is underdiagnosed, only recorded for roughly 9% of patients. Malnourished patients experience poor health outcomes and burden the healthcare system with higher hospitalization costs, higher readmission rates, and longer average length of stay.

One quality improvement study of 27 MQii Learning Collaborative hospitals found a statistically significant reduction in risk of 30-day readmissions in hospitals that implemented malnutrition quality improvement practices. Use of the individual eCQMs enabled Learning Collaborative hospitals to quantify impact of their malnutrition care interventions and measure quality improvement. Many additional publications demonstrate the improved quality and reduced costs that result from implementing MQii activities. If included in the FY 2023 final IPPS rule, hospitals across the US will be incentivized to measure their own performance by reporting the GMCS through the Hospital IQR Program. This inclusion would expand opportunities for additional hospitals to improve their malnutrition care performance and see similar health outcome, quality performance, and cost-reduction improvements. Hospitals that elect to report on the measure can leverage existing MQii resources to improve their malnutrition care practices and potentially reduce malnutrition-associated costs.

Positive Broader Implications of GMCS Implementation

Finalizing the inclusion of GMCS in the Hospital IQR Program would further demonstrate the CMS’s commitment to improving malnutrition-related health outcomes and promoting quality nutrition care. The CMS previously included a nutrition-related Merit-Based Incentive Payment System (MIPS) Improvement Activity (IA) in the FY 2022 Medicare Physician Fee Schedule Final Rule. The MIPS IA, entitled “Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols,” was developed by the MQii leadership team and was the first nutrition-focused IA implemented by the CMS. As the CMS continues to prioritize health equity and address social determinants of health, improving access to quality nutrition care can help providers work upstream and prevent costly health events for even the most vulnerable patient populations.

Support for the MQii is provided by Abbott. Avalere retained full editorial control.

Avalere and the MQii team can support hospitals and health systems along their malnutrition care quality improvement journey. To receive Avalere updates and learn how we support clients in quality improvement, connect with us.