Expert: CMS Takes Significant Step to Improve Sepsis Care in 2024 IPPS Rule

The Centers for Medicare & Medicaid Services make SEP-1 sepsis care bundle a pay-for-performance measure.

The inclusion of the Severe Sepsis and Septic Shock Management Bundle (SEP-1) into Medicare's Hospital Value-Based Purchasing Program (VBP) is a significant advancement for sepsis care, the chair of the Sepsis Alliance Board of Directors says.

Sepsis is an extreme reaction to infection that can be life-threatening. According to the Centers for Disease Control and Prevention, about 1.7 million American adults develop sepsis annually and about 1 out of 3 hospital patients who die during their hospitalization had sepsis.

Last week, the Centers for Medicare & Medicaid Services (CMS) included SEP-1 in the VBP program as part of the FY 2024 Hospital Inpatient Prospective Payment System and Long-Term Care Hospital Prospective Payment System Final Rule (IPPS). A CMS spokesperson told HealthLeaders that the move is designed to improve sepsis care.

"CMS has finalized the inclusion of SEP-1 in the VBP program in recognition of the importance of improving sepsis care, a leading cause of morbidity and mortality. The SEP-1 measure has been included in the Hospital Inpatient Quality Reporting Program since FY 2017. Since the inclusion of the measure, the national average measure performance has increased 8%. In order to continue to drive improvement on outcomes of this critical condition, we finalized adding the measure into the VBP program to link performance on the measure to hospital payment," the spokesperson said.

A research article published by Spartan Medical Research Journal summarizes the SEP-1 protocols. "There are two bundles included in the SEP-1 measure: the severe sepsis bundle and the septic shock bundle. The severe sepsis bundle requires lactate measurements, blood cultures and broad-spectrum antibiotics administration within three hours of sepsis identification followed by repeat lactate measurements within six hours if the initial lactate level is elevated. The septic shock bundle adds three additional requirements: 1. 30 mL/kg of IV fluids within three hours; 2. vasopressors within five hours for persistent hypertension; and 3. repeat volume assessment within six hours."

The inclusion of SEP-1 in the VBP program makes SEP-1 a pay-for-performance measure, says Steven Simpson, MD, professor of medicine at the University of Kansas and chair of the Sepsis Alliance Board of Directors.

"For several years, there have been financial penalties if your hospital was not participating in reporting how well they were doing with the various care measures that are part of SEP-1. It is believed by CMS and others, including the Sepsis Alliance, that if you do these things in your care of sepsis patients the outcomes will be better. If you are a hospital larger than a critical access hospital, you were required to report your SEP-1 activities or you would experience a Medicare reimbursement penalty. When CMS adopts SEP-1 as part of the Hospital Value-Based Purchasing program, you will not only have to report but also meet standards for performance. If you do not meet those standards, you will have to forfeit a small percentage of your Medicare reimbursement," he says.

Including SEP-1 in the VBP program gives hospitals an incentive to improve their sepsis care, Simpson says. "With a reporting-only standard for SEP-1, there is no requirement that you get better at taking care of sepsis patients. Under the Hospital Value-Based Purchasing program, hospitals will be required to meet standards for how often they comply with the SEP-1 bundle in order to achieve full payment. It is going to be an incentive to perform better. It comes down to dollars. Many hospitals operate on relatively thin margins of 1% to 2%, so losing any of your Medicare reimbursement is important. For many hospitals, Medicare is the largest payer, so this becomes a financial incentive for hospitals to do better."

Compliance with SEP-1 saves lives, he says. "CHEST published a paper on the impact of SEP-1 on Medicare beneficiaries last year, and they found that the bundle reduced sepsis mortality by about 5 percentage points. So, if you are compliant with SEP-1 compared to if you are not compliant, you have better outcomes and lower mortality. In the Medicare research, mortality was reduced from about 27% to about 22%."

Hospitals can take several steps to improve SEP-1 compliance, Simpson says. "One of the things that hospitals need to do is to have a physician champion who cares deeply about improving sepsis care. Some doctors do not understand that following the SEP-1 bundle requirements makes a difference, so you must educate doctors about the SEP-1 bundle. You must educate doctors and nurses to work as a team, to identify sepsis early, and to know when to trigger the sepsis bundle appropriately so patients get early treatment. It also helps if a hospital can assign particular individuals to monitor compliance with the SEP-1 bundle—you need to have data collection in place if you want to improve."