Non-compliant hospices will see 2% penalty on Oct. 1, 2022
Hospices need to be aware of two important hospice quality reporting deadlines occurring over the next few days, SimiTree compliance experts say, to avoid a 2% financial penalty in fiscal year 2023 and prevent inaccurate information from being publicly reported on the next Care Compare website refresh.
The two deadlines are:
- Thursday, Aug. 11 will be the last day for a hospice to submit a request of reconsideration of non-compliance for the annual reconsideration process for the Hospice Quality Reporting Program (HQRP) Annual Payment Update (APU) determinations. A 2% penalty in Medicare reimbursement is at stake.
- Monday, Aug. 15 will be the last day to make any necessary corrections to publicly reported measures the first quarter of 2022. Data will be used for the next refresh of the hospice Care Compare web site.
Requests for reconsideration
The Hospice Item Set or HIS is a set of data elements that extracts data from the medical record to calculate quality measures. Hospices are required to electronically complete and submit HIS data to the Centers for Medicare and Medicaid Services (CMS) as part of the HQRP. If hospices do not meet threshold requirements for HIS submission and participate in the Hospice CAHPS Survey, they may face lower reimbursement as a result.
HIS data must be submitted for both admission and discharge, and a timeframe applies. Hospices must submit at least 90% of all HIS records within 30 days of the admission or discharge.
In addition, hospices must participate in the Hospice CAPHS Survey each month, with an approved third-party vendor submitting CAHPS data that meets quarterly deadlines.
“If these two requirements are not met, the hospice will be determined to be non-compliant with HQRP and may be subject to a reduction in payment for the next fiscal year,” said SimiTree Senior Manager Maureen Kelleher, Clinical Operations Consulting.
The penalty for non-compliance for fiscal year 2023 will be 2% of the Annual Payment Update, she said.
“But hospices should note that the amount of this penalty for non-compliance will increase in subsequent years, increasing to 4% in 2024,” Kelleher said.
“And the data used for that increase will be from this year, so it is important for hospices to focus right now on meeting that 90% threshold for submitting all HIS records within 30 days of the admission or discharge.”
Notices of non-compliance
CMS notifies hospices that are non-compliant with HQRP in two ways:
- A letter of notification of non-compliance may be sent via the Medicare Administrative Contractors (MACs), or
- An electronic letter may be sent via the iQIES - Certification and Survey Provider Enhanced Reporting (CASPER) system.
“Hospices should look for the letter and be sure to access their iQIES/CASPER system since either letter serves as notice of HQRP non-compliance,” Kelleher said.
If the hospice believes an error has been made, or that it meets an exception such as being a new hospice or having experienced a qualifying disaster, it is allowed to request a reconsideration. Appropriate documentation will be required to support the hospice’s position.
The last day for hospices to request a reconsideration prior to fiscal year 2023 will be Aug. 11.
“Otherwise, non-compliant hospices will see that 2% penalty beginning Oct. 1,” Kelleher said.
Care Compare data
A second important deadline for hospices occurs Aug. 15, Kelleher said. That will be the last date for making corrections to Q1 quality measures used for public reporting on Care Compare.
Care Compare on Medicare.gov is the official CMS website for publicly reporting quality measures for care provided by health care providers. Providers may view their quality measure data in advance and submit any necessary corrections via CASPER.
Updates made after the correction deadline will not appear in subsequent Care Compare refreshes, so SimiTree consultants say it is important for providers to review records for accuracy and make changes prior to the deadline.
For more information, visit the HQRP Requirements and Best Practices webpage.
SimiTree can help
Do you have HQRP compliance questions? SimiTree’s qualified and experienced consultants can provide the guidance your hospice needs to stay abreast of changing regulations.
We help with both requests for reconsideration and appeals, and our knowledgeable consultants can help your organization put into place an effective operational improvement plan for meeting HIS submission requirements to avoid future penalties.
Our qualified team of current and former surveyors can also help you drill down on survey readiness, ensuring compliance with new CMS scrutiny on key Conditions of Participation for hospice.
Our financial consultants can strengthen your revenue cycle, insulating your hospice against increasing Medicare payment-related audits.
Use the form below to reach out to us, and let’s get started helping your hospice grow stronger and healthier overall.