Inpatient Rehabilitation Facility (IRF) Quality Reporting Program (QRP) Reconsideration and Exception & Extension

This webpage provides information and updates related to the reconsideration and exception and extension process for the IRF QRP. You will also find guidelines for submitting reconsideration requests and requests for exceptions and extensions.

IRF QRP: Natural Disaster Protocol

For disasters impacting the Post-Acute Care (PAC) QRPs, a disaster-specific memo will be posted to the Downloads section of this webpage with additional information, including impacted counties and quality reporting quarters.

Updates

Reporting Exception Granted Due to Hawaii Kona Low Weather Systems and Commonwealth of the Northern Mariana Islands Super Typhoon Sinlaku

The Centers for Medicare & Medicaid Services (CMS) is granting extraordinary circumstance exceptions¹ under certain Medicare quality reporting and value-based purchasing programs to providers and facilities located in areas affected in the state of Hawaii by the Hawaii Kona Low Weather Systems, and in the Commonwealth of the Northern Mariana Islands by Super Typhoon Sinlaku, as identified by both Department of Health and Human Services (HHS) Public Health Emergency (PHE) declarations (PHE | Hawaii - Severe Storms; PHE | Northern Mariana Islands – Super Typhoon Sinlaku) and the Federal Emergency Management Agency (FEMA) major disaster declarations (FEMA | HI Major Disaster Declaration (4909); FEMA | Northern Mariana  Islands Major Disaster Declaration (4910)), to support these providers and facilities which may require the focusing or redirecting of resources toward accommodating circumstantial care needs of their patients and addressing potential infrastructure challenges affecting their healthcare operations.

Affected areas covered by these exceptions are detailed on the Designated Areas: Disaster 4909 and Designated Areas: Disaster 4910 pages, under the section Public Assistance, designations PA-A and PA-B, of the FEMA website. If FEMA expands the major disaster declaration to include additional affected areas at a later date and it is operationally feasible, CMS will likewise extend reporting requirement exceptions to accommodate these areas but will not necessarily publish updated communications.

At the time of this communication, the exceptions being granted are for the reporting requirements and deadlines as detailed in the table below:

1 The terminology “exception” is used as a general term intended for ease of reference to collectively refer to extraordinary circumstance exception (ECE) policies established under separate programs and may not be consistent with the specific terminology established under each individual program.

Additional Reporting Requirement Exceptions

Providers and facilities located within a designated area listed in the FEMA disaster declaration who seek an exception for a reporting requirement not covered by this table may request an individual exception using the applicable ECE request process for the respective program(s). CMS will assess and decide upon each ECE request on a case-by-case basis.

Merit-based Incentive Payment System (MIPS)

In addition to the above table, the MIPS Automatic Extreme and Uncontrollable Circumstances (EUC) policy will be applied at the individual level to MIPS eligible clinicians identified as located in the aforementioned affected areas. Additional information on this policy can be found in the 2026 MIPS Automatic EUC Factsheet.

Exception and Extension Requests Overview

The Centers for Medicare & Medicaid Services (CMS) provides Inpatient Rehabilitation Facilities (IRFs) an opportunity to request an exception or extension from the program’s reporting requirements in the event they were unable to submit quality data due to extraordinary circumstances beyond their control. IRFs affected by a natural or man-made disaster or other extraordinary circumstances may request an exception and extension by filing an Extraordinary Circumstance request.

Submission of Exception and Extension Process in Cases of Disaster or Extraordinary Circumstances

All IRFs requesting an exception or extension must submit the request within ninety (90) days of the event. CMS may grant the exception or extension for one or more quarters. CMS may also grant the exception and extension to IRFs that have not requested one when an extraordinary circumstance, such as an act of nature, affects an entire region or locale. CMS will communicate through routine channels when such determination is made.

IRFs must request an exception or extension via email with the subject line, “Disaster Exception or Extension Request” and send it to IRFQRPReconsiderations@cms.hhs.gov. The email must include the following information:

• IRF CMS Certification Number (CCN)
• IRF Business Name
• IRF Business Address
• CEO or CEO-designated personnel contact information including name, email address, telephone number, and physical mailing address, i.e. not a post office box
• Description of the event (examples provided above) associated with the reason for requesting the exception and extension
• A date when the IRF believes that it will again be able to submit IRF QRP data and a justification for the proposed date
• Any other documentation supporting the rationale for seeking the exception and extension

Response from CMS

CMS will provide an email acknowledgment upon receipt of the exception and extension request. CMS will notify the CEO or CEO-designated contact provided in the request with the decision via email.

Reconsideration Request Overview

In the Fiscal Year (FY) 2017 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) Final Rule (81 FR 52125), the Centers for Medicare & Medicaid Services (CMS) clarified that in order to notify IRFs found to be non-compliant with the reporting requirements set forth for a given payment determination, the Quality Improvement and Evaluation System (QIES) mechanism would be an additional method to administer such notifications. In the FY 2019 IRF PPS Final Rule (83 FR 38561 through 38562), CMS expanded the methods by which IRFs would be notified of non-compliance with the IRF QRP requirements for a program year. Any IRF determined to be non-compliant with the IRF QRP requirements may be subject to a two percentage (2%) point reduction in their Annual Increase Factor (AIF).

IRFs determined to be non-compliant following the May 15^th submission deadline will receive a letter of notification from CMS distributed and placed into the facilities’ “My Reports” folders in the Internet Quality Improvement Evaluation System (iQIES), that includes the reason(s) for failing AIF compliance. Additionally, a separate letter is distributed by the Medicare Administrative Contractors (MACs).

News and updates regarding the distribution of the non-compliant letters and the reconsideration period may be found on IRF QRP Spotlights & Announcements webpage in late spring/early summer. Messaging will include the method of communication for the notices, instructions for sending a reconsideration request, and the final deadline for submitting a reconsideration request.

What is Reconsideration?

Reconsideration is a request for a review of the initial CMS compliance determination for a given IRF, for a given FY.

When Would an IRF Submit a Reconsideration Request?

IRFs may file for reconsideration if they believe the finding of non-compliance is an error.

Important Note: A request for reconsideration due to a deficiency in the IRF reporting of data as required in the IRF QRP due to a disaster is separate and aside from the waiver requirements and purposes pursuant to 42 CFR §412.614.

Reconsideration Request Process

IRFs disagreeing with the initial determination of non-compliance and the impending payment reduction decision may submit a request for reconsideration to CMS within thirty (30) days from the date at the top of the non-compliance notification letter. CMS will not accept any requests submitted after the thirty (30) day deadline.

Extension to File a Reconsideration Request

In accordance with § 412.634(d) (as amended by the FY 2026 IRF PPS Final Rule), an IRF that experiences an extraordinary circumstance within the 30-day reconsideration period (for example, a natural or man-made disaster) may request an extension to file a reconsideration request.

The IRF must submit the extension request to CMS within 30 calendar days of the non-compliance notification via email to: IRFQRPReconsiderations@cms.hhs.gov

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.

IRFs are required to submit their request to CMS via email with the subject line: IRF ACA 3004 Reconsideration Request and include the IRF CMS Certification Number (CCN) e.g., IRF ACA 3004 Reconsideration Request, XXXXXX). The request must be sent to the following email address: IRFQRPReconsiderations@cms.hhs.gov.

The email request must contain the following information:

• IRF CCN
• IRF Business Name
• IRF Business Address
• CEO or CEO-designated representative contact information, including name, email address, telephone number, and physical mailing address, i.e. not a post office box
• CMS identified reason(s) for non-compliance from the non-compliance notification letter
• Information supporting the IRF belief that the non-compliance finding is an error, or evidence of the impact of extraordinary circumstances that prevented timely submission of data

The request for reconsideration must be accompanied by supporting documentation demonstrating compliance. CMS will not review requests that fail to provide the necessary documentation nor accept any files that are larger than 20 MB (megabytes). Supporting documentation may include any or all of the following:

• Proof of submission
• Email communications
• Data submission reports from the iQIES
• Data submission reports from the National Healthcare Safety Network (NHSN)
• Proof of previous waiver approvals (including disaster exceptions/exemptions)
• Notification of the CCN activation letter to prove that the CCN was not activated by the end of the reporting quarter
• Other documentation supporting the rationale for seeking reconsideration

IMPORTANT:

Never include patient information (i.e., protected health information [PHI], patient identifiable information [PII], or other Health Insurance Portability and Accountability Act [HIPAA] data) in the documentation being submitted to the Centers for Medicare & Medicaid Services (CMS) for review. Submitting patient-level data or PHI/PII may be a violation of your facilities’ policies and procedures as well as a violation of federal regulations (that is, HIPAA).

Any documentation submitted for review that includes PHI or PII will not be accepted or reviewed for reconsideration. Please redact any PHI/PII prior to sending. If any of the documents included in a reconsideration request contain PHI/PII, the entire request will be rejected.

Review Data Submission Requirements

Please refer to the IRF Quality Reporting Data Submission Deadlines webpage for more information about data submission requirements.

Reconsideration Request Process Timeline

Below is the estimated reconsideration process timeline for a fiscal year's payment determination:

• June — July: CMS issues notices of non-compliance to IRFs that failed to meet quality reporting requirements via a letter sent using at least one of the following methods:
  • The Internet Quality Improvement and Evaluation System (iQIES)
  • The Medicare Administrative Contractor (MAC) via,
    • The United States Postal Service (USPS) or
    • Email distribution
• July — August: Reconsideration requests are due to CMS by the date indicated on the notification of non-compliance from CMS.
• July — August: CMS provides an email acknowledgment within five (5) business days upon receipt of reconsideration request.
  • Please Note: The IRFQRPReconsiderations@cms.hhs.gov email account will send an auto-reply upon receipt of your email. This email auto-reply is not the CMS acknowledgment of receipt. If you do not receive a follow-up acknowledgment of receipt within five (5) business days, please check to ensure that the overall size of the reconsideration request does not exceed the 20 MB limit and resubmit your request prior to the deadline.
• September: IRFs are notified of the agency’s decision on the reconsideration requests via letter from the MACs and CMS.
• October: Annual Increase Factor (AIF) penalty will be imposed on all providers found to be noncompliant with quality reporting requirements.

Filing an Appeal

Inpatient Rehabilitation Facilities (IRFs) 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 PRRB Review Instructions webpage. You must follow the instructions listed on that website to file with the PRRB.

If the amount in controversy is at least $1,000, but less than $10,000, then Federal Specialized Services (“FSS”) will manage the dispute as an Intermediary Hearing. Requests for an Intermediary Hearing should be sent electronically to intermediary@fssappeals.com.

For More Information

For additional assistance, IRFs may submit questions related to the reconsideration or exception and extension request to IRFQRPReconsiderations@cms.hhs.gov.

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