Older Adults Will Benefit from a New Proposed CMS Malnutrition Quality Measure

There is exciting nutrition news, just in time for Older Americans Month. The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that includes the Global Malnutrition Composite Score (GMCS) as an optional measure for the Hospital Inpatient Prospective Payment System (IPPS) for Fiscal Year 2023. The GMCS is a comprehensive tool for assessing quality hospital care for older patients (ages 65 and older) who are at risk of malnutrition and can help advance health equity and better quantify and improve nutrition care.

Malnutrition Quality Measure Helps Advance Health Equity

In its proposed IPPS rule, CMS commented, “One factor contributing to the burden of malnutrition is health disparity across racial and ethnic groups.” Indeed, 2019 data from the Malnutrition Quality Improvement Initiative (MQii) Learning Collaborative, which now reflects more than 1.5 million patient records from hospitals across the United States, document substantial disparities in malnutrition diagnoses and readmissions, including that non-Hispanic Black individuals with malnutrition experienced a readmission rate of greater than 26%, while the rate was less than 19% among non-Hispanic White individuals.

Adoption of the GMCS measure has been proposed as one way to help reduce drivers of inequitable access to malnutrition care and nutritious food. It is not surprising then that CMS further noted in their proposed rule, “We believe adopting a malnutrition measure would address several priority areas identified in the CMS Equity Plan for Medicare, including evaluating impacts of disparities, integrating equity solutions across CMS programs, and increasing the ability of the healthcare workforce to meet the needs of underserved populations.”

Malnutrition Quality Measure Helps Better Quantify and Improve Nutrition Care

When malnutrition is not identified and treated it can lead to poor health outcomes. CMS noted in its proposed rule, “Hospitalized adults with a diagnosis of malnutrition have a longer length of stay, higher costs, more comorbidities, five times the likelihood of death, and greater risk of infectious disease and injury compared with other adult inpatients without malnutrition.”

Stakeholders can comment until June 17, 2022, on the need for and importance of the Global Malnutrition Composite Score quality measure.

CMS also said, “nearly 13 million seniors are hospitalized each year“ and “between 910,000 and 6.5 million hospitalized seniors may experience malnutrition.” The GMCS quality measure is urgently needed to help address the under-diagnosis of malnutrition because currently malnutrition is only recorded for less than less than 9% of patients.

The GMCS was developed by the Academy of Nutrition and Dietetics and Avalere Health to measure quality malnutrition care delivered to patients ages 65 and older in the inpatient setting. It is calculated as an average of the performance scores for four component measures for patients ages 65 years and older:

  • Malnutrition screening of patients
  • Nutrition assessment of patients at risk for malnutrition
  • Appropriate malnutrition diagnosis documentation for patients identified as malnourished
  • Documented nutrition care plan in the medical record for patients identified as malnourished.

Registered Dietitian Nutritionists (RDNs) have championed the implementation of the individual component measures of the GMCS in more than 250 hospitals as part of a national hospital learning collaborative of the MQii. One quality improvement study of 27 MQii Learning Collaborative hospitals found implementing these practices led to a statistically significant reduction in risk of 30-day readmissions.

What’s Next

The Hospital IPPS is how Medicare reimburses most hospitals for acute care hospital inpatient stays using set rates under Medicare Part A. IPPS hospitals are required to report on a specific number of electronic clinical quality measures (eCQMs) and for FY 2023 the GMCS measure has been proposed as a eCQM measure that hospitals could self-select. Including the GMCS measure in the final FY 2023 IPPS rule—expected to be released in early fall—would help hospitals improve malnutrition care and reap the patient and health outcome benefits that have been shown by MQii learning collaborative hospitals.

As CMS continues to prioritize health equity and address the social determinants of health, improving access to quality nutrition care can help providers prevent unnecessary and costly health events for vulnerable patient populations. If it is part of the final IPPS rule, the GMCS measure would be the first nutrition-focused quality measure included in any CMS payment program, and one of the few that would help advance health equity.

More information about the GMCS measure will be shared in an upcoming webinar, Advocating for Older Adult Nutrition and Quality Measurement on June 8, 2022 1–2 p.m. EDT with the International Council on Active Aging and Defeat Malnutrition Today. Please register here.

Dana Buelsing Sowards, MS, CAPM, LSSGB, is manager of quality standards operations at the Academy of Nutrition and Dietetics. Mujahed Kahn, MBA, RDN, LDN, FAND, is senior manager of quality improvement at the Academy of Nutrition and Dietetics.

Please send comments prior to June 17, 2022, on the need for and importance of the Global Malnutrition Composite Score quality measure.