I'm a healthcare quality executive with over 30 years of clinical and administrative experience driving organizational transformation. As founder of Just Performance, I help organizations achieve sustainable performance improvement through strategy deployment and best practices in quality, patient safety, value-based care, and integration of technology.
Through my newsletter, I share practical insights on healthcare quality leadership, performance excellence, and strategic transformation—bridging executive strategy with operational reality for healthcare leaders navigating complex challenges.
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The sepsis readmission penalty is coming — and most hospitals aren’t ready
Published 26 days ago • 3 min read
Issue #2
July 2026
Healthcare Quality & Patient Safety Intelligence
A monthly letter from Jennifer Giusti at Just Performance, LLC
The Pulse
Most hospitals track sepsis, readmissions, bundled payments, and eCQMs as separate problems owned by separate teams. CMS just made them one problem. The FY 2027 IPPS proposed rule doesn’t raise the bar — it raises the floor and then connects all the bars. If your organization hasn’t yet mapped this exposure end to end, this newsletter is a good place to begin.
This is the lens for this month's IN FOCUS segments: First, CMS's evolving "accountability stack". Then a more granular look at Sepsis as a major player in the Hospital Readmission Reduction Program (HRRP).
And, if you read to the end, you'll find my update from our farm in Georgia. Just for fun and good life balance.
— Jennifer
🔬 IN FOCUS: The CMS Accountability Stack Is Getting Taller
Hospital Harm eCQMs are being positioned for a larger role through expanded and updated eCQM requirements in the Hospital IQR and Promoting Interoperability programs. These measures are documentation-driven, not coding-driven, so performance will increasingly depend on what gets captured in the EHR in real time rather than what gets coded after discharge. If your clinical documentation workflows aren’t aligned to eCQM specifications, you’re already behind.
CMS has also proposed CJR-X, a nationwide episode-based payment model for hip, knee, and ankle replacements beginning October 2027. Most IPPS hospitals would be included, except those in TEAM or located in Maryland. Taken together, TEAM, IQR, HRRP, Hospital Harm eCQMs, Star Ratings, and CJR-X form an interlocking accountability stack where underperformance in one program compounds exposure in the others — and CMS has proposed adding sepsis readmissions to HRRP, the highest-volume readmission condition in most hospitals.
Your action: Before the final rule lands later this summer, map your performance across HRRP, Hospital Harm eCQMs, Star Ratings, and TEAM/CJR-X eligibility together — not in separate silos. The real risk picture only becomes visible when you see the stack as a system.
A note from Just Performance: If this is surfacing questions about where your organization stands inside CMS’s emerging accountability stack — where sepsis readmissions, Hospital Harm eCQMs, HRRP, Star Ratings, TEAM, and CJR-X all reinforce each other — reply to this email.
We can help you assess your readiness across the full stack and build a practical, system-level plan to close gaps.
🔬 IN FOCUS: Sepsis + HRRP: The Convergence You Need to Plan For Now
That last point deserves its own focus. CMS has proposed a 30-day, all-cause, risk-standardized readmission measure for sepsis in HRRP, with implementation targeted for a future program year. Sepsis already accounts for roughly 21.4% of all 30-day readmissions and more than $3.5 billion in annual readmission costs. When this measure goes live, hospitals without an integrated sepsis-to-discharge strategy will face simultaneous quality and financial pressure across multiple programs.
The predictors are actionable. Infection drives roughly 42% of sepsis readmissions, followed by cardiovascular, pulmonary, and renal complications. Early studies linking unemployment and tobacco use to sepsis readmission risk also point to a post-discharge intervention gap that most organizations haven’t designed specifically for sepsis survivors.
Your action: Use the time between now and the final rule to audit your sepsis program’s handoffs to discharge planning and post-acute care. If sepsis and readmissions are still managed as separate workstreams, that’s your first structural gap to close.
👀 What I'm Watching
FHIR, dQMs (digital Quality Measures), and the next phase of shared data for value-based care:
The industry is moving from quality data living in a dozen separate systems to a world where it can move on a shared data backbone.
FHIR and digital quality measures are the plumbing behind that shift, giving hospitals, plans, and ACOs a way to use the same clinical data for care delivery, reporting, and contracts instead of rebuilding it three different ways.
Groups like The Sequoia Project’s data use workgroup are focused on the practical side: making sure exchanged data is usable for value-based care, not just technically compliant.
And finally... News from The Farm
Yes, this newsletter is serious about navigating some of the biggest challenges in healthcare today. For a little mental break (also serious cuteness), I plan to share something each month from another part of my daily life - feeding horses, wrangling cows, training a puppy, and getting a good dose of Vitamin D working in the veggie garden. I hope you enjoy!
Summer has officially arrived at Mount Vernon, and the farm is buzzing. Last month we welcomed one of our thoroughbred broodmares home from Kentucky, along with her beautiful new filly, Lettie — short for Knickolette. She’s settling in well and already practicing her racing skills, sprinting for the barn at dinnertime like she’s pointing toward her first stakes race.
The veggie garden is in full swing, with tomatoes, eggplant, and far too many green beans coming on all at once. The corn is right on schedule — aiming to be “knee high by the 4th of July.” Meanwhile, Maisie, our border collie pup, is growing like a weed and taking her job seriously, herding cows, horses, and the occasional bicyclist on the gravel road that cuts through the farm.
I'm a healthcare quality executive with over 30 years of clinical and administrative experience driving organizational transformation. As founder of Just Performance, I help organizations achieve sustainable performance improvement through strategy deployment and best practices in quality, patient safety, value-based care, and integration of technology.
Through my newsletter, I share practical insights on healthcare quality leadership, performance excellence, and strategic transformation—bridging executive strategy with operational reality for healthcare leaders navigating complex challenges.
Read more from Jennifer Giusti, MPA BSN, RN, FACHE
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