About this Page
The Reconsideration Requests webpage provides information and updates related to the annual reconsideration process for the Hospice Quality Reporting Program (HQRP) Annual Payment Update (APU) determinations. On this page, you will find guidelines and processes for submitting reconsideration requests.
For questions related to content posted on this page, please contact the Reconsideration Help Desk at HospiceQRPReconsiderations@cms.hhs.gov.
For disasters impacting the Post-Acute Care Quality Reporting programs, a disaster-specific memo will be posted to the downloads section below with additional information, including impacted counties and quality reporting quarters.
Reconsideration Request Overview
Any hospice determined to be non-compliant with the HQRP requirements may be subject to a two (2) percentage point reduction in their annual payment update (APU) that becomes effective October 1. For example calendar year, CY 2018 data affects federal fiscal year, FY 2020 payment.
Any hospice found non-compliant will receive a letter of notification, which will include instructions for requesting reconsideration of this decision.
The Hospice Quality Reporting Program (HQRP) includes compliance with the requirements for the Hospice Item Set (HIS) and Consumer Assessment of Healthcare Providers and Systems (CAHPS®). In the “FY 2016 Hospice Wage Index Final Rule” (79 FR 50486 through 50487), the Centers for Medicare & Medicaid Services (CMS) finalized the Fiscal Year (FY) 2017 Hospice Quality Reporting Program (HQRP) requirements. Hospices must collect Hospice Item Set (HIS) data for all events beginning January 1, 2015 and after. Likewise, in the “FY 2014 Hospice Wage Index and Payment Rate Update” final rule (78 FR 48233), CMS stated they would start the national implementation of the Consumer Assessment of Healthcare Providers and Systems (CAHPS®). For calendar year 2015 (FY2017) and after, CMS considers both HIS and CAHPS® survey data submitted by hospices to CMS, beginning on or after January 1, through December 31, to determine the APU compliance threshold.
What is Reconsideration?
Reconsideration is a request for a review of the non-compliance decision prior to the two (2) percentage point reduction in the hospice’s annual payment update (APU) taking effect on October 1. For HQRP, hospices can be found to be non-compliant if they are non-compliant with:
- Either HIS or CAHPS® Hospice Survey OR
- Both HIS and CAHPS® Hospice Survey.
When Would a Hospice Submit a Reconsideration Request?
Hospices may file for reconsideration if they receive a letter of HQRP non-compliance and believe the finding of non-compliance is in error. Hospices that want to have their circumstances reviewed by CMS must file for a reconsideration request.
NOTE: If a hospice is found non-compliant with HQRP, then it is subject to the 2% reduction in APU. This means even if the hospice thinks it meets an exception such as newness or related to a disaster, it must prove it during the reconsideration process by providing appropriate documentation to support the hospice’s position.
Please review this HQRP reconsiderations page for details about how to submit a reconsideration. Failure to submit a timely HQRP reconsideration automatically subjects any hospice non-compliant with HQRP to the 2% APU reduction for that fiscal year.
Reconsideration Request Process
CMS will notify hospices that are non-compliant with HQRP two ways; one via the Medicare Administrative Contractors (MACs) and also an electronic letter via the QIES - Certification and Survey Provider Enhanced Reporting (CASPER) system. Hospices should look for the letter and be sure to access their CASPER system since either letter serves as notice of HQRP non-compliance. Hospices that receive a letter of non-compliance must submit a request for reconsideration to CMS within thirty (30) days after the date documented on the non-compliance notification letter distributed electronically using QIES. CMS will not accept any requests submitted after the thirty (30) day deadline.
The 2019 deadline for reconsiderations is August 15th, 2019.
Create a Reconsideration Request
Please note: The only method for submitting reconsideration requests is via email.
Requests submitted by any other means will not be reviewed for reconsideration.
Hospices are required to submit their request to CMS via email.
Please include the following in the subject line: “Hospice ACA 3004 Reconsideration Request” and the hospice’s CMS Certification Number (CCN) (e.g., Hospice ACA 3004 Reconsideration Request, XXXXXX). The request must be sent to the following email address: HospiceQRPReconsiderations@cms.hhs.gov.
The email request must include the following information:
- The Hospice CMS Certification Number (CCN)
- The Hospice Business Name
- The Hospice Business Address
- CEO or CEO-designated representative contact information, including name, email address, telephone number, and physical mailing address
- CMS identified reason(s) for non-compliance from the non-compliance notification letter
- Information supporting the hospice belief that non-compliance is in error, or evidence of the impact of extraordinary circumstances which prevented timely submission of data
- The request for reconsideration must be accompanied by supporting documentation demonstrating compliance. CMS will be unable to review any request without the necessary documentation. Supporting documentation may include any or all of the following provided as examples:
- Email communications
- For HIS reporting, evidence of HIS transmissions during the reporting period (e.g. an HIS Final Validation Report from the CASPER system showing a timely submission date).
- For HIS reporting, proof of previous exemption/extension approval for the prescribed reporting period.
- For HIS reporting, notification of the CCN activation letter to prove that the CCN was not activated by November 1st.
- For CAHPS® reporting, the hospice must have served fewer than 50 survey-eligible decedents/caregivers during the reporting period, evidence that the hospice filed the Participation Exemption Request Form by the deadline date.
- For CAHPS® reporting, evidence that the hospice continuously collected data and submitted data to the CAHPS® Hospice Survey Data Warehouse during the required timeframe.
In its review of the hospice’s documentation, CMS will determine whether evidence to support a finding of noncompliance has been provided by the hospice. The determination will be made based solely on the documentation provided. CMS will not contact the hospice to request additional information or to clarify incomplete or inconclusive information. If clear evidence to support a finding of compliance is not present, the 2 percentage point reduction will be upheld. If clear evidence of compliance is present, the reduction will be reversed.
Please note: Never include patient information (i.e. protected health information (PHI), patient identified information (PII), or other Health Insurance Portability and Accountability Act (HIPAA) violations) in the documentation being submitted to CMS for review. This includes attaching HIS-Admission or HIS-Discharge records and sending to CMS via email. Email is NOT a secure transmission product and any PHI/PII sent via email will enact security violation protocol prompting involvement by the CMS security offices.
- Provider-initiated requests for exemption or extension for extraordinary circumstances
- CMS-initiated waivers for exemption or extension for extraordinary circumstances that are based on FEMA designated natural disasters.
Review Data Submissions---Helpful Information
Helpful information on how to review the submitted data is available on the HQRP webpages, Hospice Quality Reporting Program, CMS.gov website.
Reconsideration Request Process Timeline
Estimated reconsideration process timeline:
- June - CMS issues notices of non-compliance to hospices that failed to meet the hospice quality reporting requirements.
- June - July - Reconsideration requests are due to CMS thirty (30) days from the date on the notification of non-compliance
- June - July - CMS provides an email acknowledgement within five (5) business days upon receipt of the reconsideration request
- September - CMS notifies hospices of the Agency’s decision on the reconsideration requests.
- October 1---Any hospice determined to be non-compliant is subject to the 2% reduction in their APU for that fiscal year.
Response from CMS
CMS will provide an email acknowledgement upon receipt of the reconsideration request. CMS will notify the hospice of its decision to any reconsideration via the Medicare Administrative Contractors (MACs) and also an electronic letter via the QIES - Certification and Survey Provider Enhanced Reporting (CASPER) system. Hospices should look for the letter and be sure to access their CASPER system since either letter serves as notice of CMS’ decision.
Filling an Appeal
Under “Filing an Appeal” replace the existing paragraph with the following text:
Hospices dissatisfied with the reconsideration ruling may file a claim under 42 CFR Part 405, Subpart R (a Provider Reimbursement Review Board [PRRB] appeal). Details are available on the CMS.gov PRRB Review Instructions website. You must follow the instructions listed on that website to file with the PRRB.
If the estimated impact of your penalty is $10,000 or below, you should file the appeal with Federal Specialized Services, the ASC. These appeals are called Contractor Appeals. Information on these appeals is available on your MAC’s website.
HQRP Quick Reference Guide now available
A Quick Reference Guide for the Hospice QRP FY 2020 is now available on the in the downloads section. The guide includes frequently asked questions, information on QRP help desks, and helpful links to additional resources for the Hospice QRP.
Quarterly Updates---Please Sign Up
CORMAC is a CMS contractor. CORMAC sends informational messages related to hospice reconsideration issues on a quarterly basis. Their latest outreach communication can be found in the Download section of this page. If you want to receive CORMAC’s quarterly emails, then add or update the email addresses to which these messages are sent by emailing to: QRPHelp@swingtech.com and be sure to include your facility name and CMS Certification Number (CCN) along with any requested updates.
For More Information
For additional assistance, hospices may submit questions related to the reconsideration request to: HospiceQRPReconsiderations@cms.hhs.gov.