Palmetto HQRP Non-Compliance: A Critical Wake-Up Call for Hospices

Attention hospice providers: Are you confident in your HQRP compliance? Recent Palmetto GBA non-compliance notices have sent shockwaves through the hospice community, highlighting the critical importance of mastering hospice quality reporting requirements. With potential 4% Medicare reimbursement cuts looming, the stakes for regulatory compliance have never been higher.

This blog post delves into the urgent HQRP compliance challenges facing hospices today and offers expert insights on navigating complex Medicare audits and avoiding costly penalties. Whether you’re struggling with HIS submissions, CAHPS survey compliance, or overall hospice regulatory adherence, understanding these issues is crucial for your agency’s financial health and operational success. Read on to discover how to safeguard your hospice against compliance pitfalls and ensure quality reporting meets CMS standards.

Everything you need to know about HQRP & recent news

The Hospice Quality Reporting Program (HQRP) was established by CMS in 2014 under section 1814(i)(5) of the Social Security Act. As per CMS, “HQRP includes data submitted by hospices through the Hospice Item Set (HIS) data collection tool, data from Medicare hospice claims, and an experience of care survey, the Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Survey.” All Medicare-certified hospice providers must comply with these reporting requirements to avoid significant financial penalties and maintain their standing in the industry.

The HQRP is currently a “pay-for-reporting” program, meaning that timely submission and acceptance of complete data determine compliance rather than performance levels.

The Recent Palmetto GBA non-compliance notices:

Recently, Palmetto GBA, one of the nation’s largest Medicare Administrative Contractor, issued non-compliance notices to 444 hospice agencies in Jurisdiction M. This alarming development underscores the critical need for hospices to prioritize HQRP compliance and seek expert assistance in navigating complex regulatory requirements.

Understanding the Palmetto HQRP Non-Compliance

Let’s review the key points from the Palmetto GBA release:

Hospice Item Set (HIS) Compliance:

Hospices must submit at least 90% of all required HIS records within the 30-day submission deadline.
This timeliness compliance threshold is crucial to avoid percentage-point reductions.

CAHPS® Hospice Survey Compliance:

Survey readiness is essential. It’s more important than ever for hospice agencies to incorporate survey-ready practices, processes, and procedures into their daily operations to withstand survey scrutiny and deliver services aligned with best practices and quality care.

Hospices must collect data monthly using the CAHPS® Hospice Survey.
A CMS-approved vendor must submit a total of 12 months of data to the CAHPS® Hospice Survey Data Warehouse.
Each quarterly submission must be complete (3 months’ worth of data) and accepted by the quarterly deadline.

Consequences of non-compliance for hospice agencies

The Social Security Act directs the Secretary to reduce the market basket update (Annual Payment Update, or APU) for non-compliant hospices. Beginning with FY 2024 and for each subsequent year, the penalty will increase from 2 to 4 percentage points for hospices that do not comply with the HQRP. Compliance is based on the timely, successful submission of HIS and CAHPS® Hospice Survey data, not on facility-level performance.

Implications for the 444 targeted hospice agencies:

For FY 2024, hospices must submit at least 90% of all HIS records within 30 days of the event date (patient’s admission or discharge) for patient admissions/discharges occurring 1/1/22 – 12/31/22. They must also participate monthly in the CAHPS® Hospice Survey from 1/1/2022 to 12/31/2022. Non-compliance affects the agency for the following year with a deduction from all Medicare patients’ payments.

Common HQRP challenges and hospice solutions

Here are some of the most common reasons for HQRP non-compliance:

Data quality issues
System failures
Inadequate staff training
Lack of timely review and submission of HQRP data

SimiTree’s risk mitigation services:

SimiTree offers comprehensive risk mitigation services tailored to hospice agencies’ unique needs. Our team of experts can help identify potential vulnerabilities in your HQRP reporting processes, implement effective monitoring systems, and provide targeted staff training to ensure consistent compliance. A team like ours can assist in all things:

Reviewing submission data for completeness and timeliness
Implementing robust monitoring processes
Providing education on HQRP manuals and reporting requirements

Preventing future non-compliance: Stay compliance with these tips

Proactive strategies for hospices:

Implement real-time monitoring of HIS and CAHPS® data submission
Establish internal quality control processes
Conduct regular compliance audits
Provide ongoing staff education on HQRP requirements

SimiTree offers a suite of compliance resources, including:

Customized training programs
Regulatory updates
On-demand expert consultation
Pre-bill audits
Assistance in developing and implementing strong compliance programs

With expertise in audit preparation, compliance program development, and ongoing regulatory support, SimiTree empowers hospices to mitigate risks and ensure continuous compliance with HQRP and other critical regulations. Our team stays abreast of the latest CMS guidelines and industry best practices to ensure your hospice agency remains compliant and competitive in an ever-changing regulatory landscape.

The severity of HQRP non-compliance:

The recent Palmetto GBA non-compliance notices are a critical wake-up call for hospice agencies nationwide. To avoid an ongoing impact on hospice reimbursement, each organization must ensure timely reporting and review of HQRP data, confirming that it is complete and submitted on time.

Don’t risk your agency’s financial health and reputation. SimiTree stands ready to partner with your hospice agency, providing the expertise and support needed to navigate complex regulatory requirements and ensure ongoing compliance.

Contact SimiTree today to schedule a comprehensive compliance assessment and discover how our tailored solutions can safeguard your hospice’s future.