Extraordinary Circumstances Extension / Exception (ECE) due to
Hurricane Michael
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The purpose of this
communication is to notify Post-Acute Care providers of the Centers for
Medicare & Medicaid Services (CMS) intent to grant quality reporting data
submission and validation exceptions to Medicare providers in several care
settings adversely affected by the devastating impact of Hurricane Michael,
including Long-Term Care Hospitals (LTCHs), Inpatient Rehabilitation
Facilities (IRFs), Hospices, Home Health Agencies, and Skilled Nursing
Facilities (SNFs). CMS is issuing exceptions for several quality reporting
data submission requirements because of possible damage to facilities and/or
systems resulting in their inability to gather or submit data, as well as the
need to prioritize immediate resources for direct patient care.
Specifically, for the
specified reporting quarter(s), as indicated in this communication, affected
providers will not be required to submit quality measure data to meet
submission requirements.
CMS is exercising its
authority to grant exceptions for data submission requirements for the above
quality reporting programs for providers located within the Federal Emergency
Management Agency (FEMA)-designated “major disaster” counties of Florida, and
Georgia listed below:
CMS recommends visiting
the FEMA website at https://www.fema.gov for the most up to date
list of counties affected by Hurricane Michael. Please note that Medicare
providers located outside of the counties covered under this memo, and in
need of an extension or exception from program requirements are required to
follow the submission process described at the bottom of this memo.
Long Term
Care Hospital Quality Reporting Program (QRP)
For the following LTCH QRP
requirements and discharged quarters listed below, CMS grants a blanket
exception for all LTCHs in the above-designated counties.
LTCHs participating in the
CMS LTCH QRP are granted an exception from the data reporting requirements of
the LTCH QRP, specifically the data submitted via the LTCH CARE Data Set
(assessment-based), and data submitted via the Center for Disease Control and
Prevention (CDC) National Healthcare Safety Network (NHSN). Claims-based
measures do not require any submission of data to CMS beyond that of data
submitted via LTCH PPS claims.
LTCHs located in covered
counties are granted an exception from reporting quality data to CMS, as
described above, for the following reporting quarters:
Inpatient
Rehabilitation Facility (IRF) Quality Reporting Program (QRP)
For the following IRF QRP
requirements and discharged quarters listed below, CMS grants a blanket
exception for all IRFs in the above-designated counties.
IRFs participating in the
CMS IRF QRP are granted an exception from the data reporting requirements of
the IRF QRP, specifically the data submitted via the assessment-based IRF-PAI
(Patient Assessment Instrument) and data submitted via the Centers for
Disease Control and Prevention (CDC) National Healthcare Safety Network
(NHSN). Claims-based measures do not require any submission of data to CMS
beyond that of data submitted via IRF PPS claims. Please note that this exception
applies to quality data only, and has no effect on the submission of the
IRF-PAI for payment purposes.
IRFs located in covered
counties are granted an exception from reporting quality data to CMS, as
described above, for the following reporting quarters:
Skilled
Nursing Facility (SNF) Quality Reporting Program (QRP)
For the following SNF QRP
requirements and discharged quarters listed below, CMS grants a blanket
exception for all SNFs in the above-designated counties.
SNFs participating in the
CMS SNF QRP are granted an exception from the data reporting requirements of
the SNF QRP, specifically the data submitted via the assessment-based Minimum
Data Set (MDS). Claims-based measures do not require any submission of data
to CMS beyond that of data submitted via Medicare FFS claims. Please note that this exception
applies to quality data only, and has no effect on the submission of the MDS
for payment or other required purposes.
SNFs located in covered
counties are granted an exception from reporting quality data to CMS, as
described above, for the following reporting quarters:
Hospice
Quality Reporting Program (QRP)
For the following Hospice
QRP requirements and discharged quarters listed below, CMS grants a blanket
exception for all Hospices in the above-designated counties.
Hospices participating in
the CMS Hospice QRP are granted an exception from the data reporting
requirements of the Hospice QRP, specifically the data submitted via the
Hospice Item Set (HIS) and the Hospice Consumer Assessment of Healthcare
Providers and Systems (Hospice CAHPS®) survey. The CAHPS Hospice Survey
exception will apply to “Q3 2018 and Q4 2018 decedents,”
or hospice patients who died between July-December 2018
Hospices located in
covered counties are granted an exception from reporting quality data to CMS,
as described above, for the following reporting quarters:
Home
Health Agencies Quality Reporting Program
For the following HH QRP
requirements and discharged quarters listed below, CMS grants a blanket
exception for all HHAs in the above-designated counties.
HHAs participating in the
CMS HH QRP are granted an exception from the data reporting requirements of
the HH QRP, specifically the data submitted via the OASIS assessment
instrument and Home Health Consumer Assessment of Providers and Systems
Survey (HH CAHPS®). Please
note that this exception applies to quality data only, and has no effect on
the submission of the Home Health OASIS for payment purposes
HHAs located in covered
counties are granted an exception from reporting quality data to CMS, as
described above, for the following reporting quarters:
We would like to note that
this exception from quality reporting requirements for the above-listed CMS
QRPs may impact the minimum case threshold counts for calculation of quality
metrics. While you can continue to submit data to CMS, any data submissions
for the above-listed exempt CY 2018 quarters will not be considered when
determining compliance related to the FY 2020 reporting requirements for your
hospital or facility. That is, you will not be held accountable for quality
data collected and submitted during the 2018 quarters identified above.
Please also note that this may affect the minimum amount of data needed to
calculate specific quality measures for public reporting purposes, in which
case CMS would suppress the applicable data on the respective Compare sites,
when quality measure data are calculated and posted.
Exception and Extension Request Process
Hospitals and Facilities
in other counties and states may submit ECE Requests for data submission
based on individual circumstances by one of the following processes:
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Thursday, November 1, 2018
Extraordinary Circumstances Extension / Exception (ECE) due to Hurricane Michael
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