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Global Malnutrition Composite Score Expansion Included in 2025 IPPS Proposed Rule

Global Malnutrition Composite Score Expansion Included in 2025 IPPS Proposed Rule

May 3, 2024

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CMS recently released the 2025 Hospital Inpatient Prospective Payment System (IPPS) Proposed Rule, which includes recommendations for quality measures for future years of the Hospital Inpatient Quality Reporting (IQR) Program. We are pleased to share that expansion of the Global Malnutrition Composite Score (GMCS) to include adults aged 18 and older has been proposed for inclusion in the Hospital IQR Program beginning with the calendar year 2026 reporting period. The MQii team from Avalere and the Academy of Nutrition and Dietetics would like to express our appreciation to the MQii member hospitals who contributed to this milestone by sharing data, providing guidance, and submitting supportive comments to the Partnership for Quality Measurement committee.

You can help ensure that this expansion is finalized by submitting supportive comments to CMS by June 10th.

When submitting comments, we recommend that you:

  • Thank CMS for proposing the expansion to ages 18+ for the GMCS
  • Recommend that CMS accelerate their proposed timeline by implementing the expansion beginning with CY 2025 reporting rather than the proposed CY 2026
    • If applicable, describe your hospital’s malnutrition care process for adult patients and how you are already delivering this care to all adult patients, so the expansion is not expected to result in any additional reporting burden for your institution

To submit comments by the June 10th deadline, please visit the comment letter submission form on regulations.gov to post your comments or attach a formal letter document. We appreciate your continued support of the GMCS to benefit patient malnutrition care.

The GMCS is not the only malnutrition-related proposal in this year’s hospital inpatient proposed rule.  CMS is also proposing to adopt two measures with direct impact to malnutrition care: the Age-Friendly Hospital structural measure and the risk-adjusted Hospital Harm: Falls with Injury electronic clinical quality measure (eCQM).  The Age-Friendly Hospital measure, which is proposed as a mandatory measure beginning with calendar year 2025, requires hospitals to attest to a set of performance elements across five domains focused on best practices in geriatric care.  One of the elements requires that the hospital screens patients age 65 and older “for risks regarding mentation, mobility, and malnutrition using validated instruments ideally upon admission, before major procedures, and/or upon significant changes in clinical status” and that positive screening for malnutrition results in “implementing nutrition plans where appropriate.  These plans should be included in discharge instructions and communicated to post-discharge facilities.”  The Hospital Harm – Falls with Injury eCQM measures the rate of patient falls in the inpatient setting that result in moderate to major injury.  To ensure that hospitals who care for sicker and more complex patients are not penalized, the measure is risk-adjusted, with present-on-admission malnutrition or weight loss identified as one of the risk factors included in the risk-adjustment model. CMS is proposing the inclusion of this eCQM in the set of measures from which hospital can self-select to meet reporting requirements, beginning with calendar year 2026 reporting.

Your hospital may choose to comment on these additional proposals as well to show overall support for elevating the importance of nutrition care in the hospital.

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