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SNF Quality Reporting Reconsideration and Exception & Extension

The Reconsideration webpage provides information and updates related to the reconsideration process for the SNF QRP.  On this page, you will find guidelines and processes for submitting reconsideration requests and requests for exceptions and exemptions.

SNF QRP: Natural Disaster Protocol

SNF’s affected by natural disaster(s) in counties that are identified through the Federal Emergency Management Agency (FEMA) as “Designated Areas” will be provided guidance and further information via this webpage with respect to data submission requirements, as it becomes available.

In addition, details and materials are also available on the CMS Emergency Response and Recovery webpage.

Please note- designated areas may be updated to add affected areas by natural disasters. Please continue to check back frequently for updates.

Updates

October 11, 2018 

Extraordinary Circumstances Extension / Exception (ECE) due to Hurricane Florence 

The Centers for Medicare & Medicaid Services (CMS) is issuing a blanket exemption for data submission for the Skilled Nursing Facility (SNF) Quality Reporting Program (QRP), for Medicare providers adversely affected by the devastating impact of Hurricane Florence.

SNF providers located within the Federal Emergency Management Agency (FEMA)-designated “major disaster” counties in North, and South Carolina will not be required to submit quality measure data to meet submission requirements for the reporting quarters specified by CMS. For a list of the designated counties and other information, see the related Email notification , issued October 11 2018

Exemptions are being issued 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.

SNF QRP exemptions

CMS has granted a blanket exemption for all SNFs in the designated counties for the following SNF QRP data submission requirements, including required quality data submitted via the Minimum Data Set (MDS):

  • Second Quarter 2018 (April 1, 2018 – June 30, 2018 for November 15, 2018, submission deadline
  • Third Quarter 2018(July 1, 2018 – September 30, 2018) for February 15, 2019 submission deadline

Please note that this exemption applies to quality data only, that is data used for the SNF Quality Reporting Program and to determine APU compliance and has no effect on the submission of the MDS for payment or other required purposes. While you can continue to submit quality data to CMS, any data submissions for the above-listed exempt CY 2018 quarters(s) will not be considered when determining compliance related to the FY 2020 reporting requirements for your SNF. That is, you will not be held accountable for data collected and submitted during the above- identified 2018 quarters. We would like to also note that this exemption from quality reporting requirements for the SNF QRP may impact the minimum case threshold counts for calculation of quality metrics, in which case CMS would suppress the applicable data on the SNF Compare site, when quality measure target periods that include Q2 & Q3 2018 data are calculated and posted. SNF providers may submit questions about this blanket exemption to SNFQRPReconsiderations@cms.hhs.gov.

For SNFs outside the FEMA-designated counties affected by Hurricane Florence, please follow the directions related to requesting an exemption or extension, as listed on the SNF Quality Reporting Reconsideration and Exception & Extension website.

Notice: February 22, 2018

Please review the Disaster Exceptions/Exemptions for Medicare Certified Providers memo located in the Download section below for additional information regarding the data reporting exceptions and exemptions related to the December California Wildfires (FEMA DR-4353).

Notice: November 02, 2017

Please review the Disaster Exceptions/Exemptions for Medicare Certified Providers memo located in the Download section below for additional information regarding the data reporting exceptions and exemptions related to the Northern California Wildfires.

Notice: September 28, 2017

Please review the Hurricane Maria - Disaster Exceptions/Exemptions for Medicare Certified Providers Affected by Severe Storms and Flooding memo located in the Download section below for additional information regarding the data reporting exceptions and exemptions related to Hurricane Maria.

Notice: September 14, 2017

Please review the Hurricane Irma - Disaster Exceptions/Exemptions for Medicare Certified Providers Affected by Severe Storms and Flooding memo located in the Download section below for additional information regarding the data reporting exceptions and exemptions related to Hurricane Irma.

Notice: August 31, 2017

Please review the Hurricane Harvey - Disaster Exceptions/Exemptions for Medicare Certified Providers Affected by Severe Storms and Flooding memo located in the Download section below for additional information regarding the data reporting exceptions and exemptions related to Hurricane Harvey.

Reconsideration

Reconsideration Request Overview

In the Skilled Nursing Facility Prospective Payment System Final Rule 80 FR (46427 through 46429) the Centers for Medicare & Medicaid Services (CMS) finalized the Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) requirements. Any SNF determined to be non-compliant with the SNF QRP requirements may be subject to a two (2) percentage point reduction in their annual payment update (APU) beginning fiscal year (FY) 2018 and each subsequent rate year.

Any SNFs found non-compliant according to the quality reporting requirements will receive a letter of non-compliance through the Quality Improvement and Evaluation System Assessment Submission and Processing (QIES-ASAP) system, as well as through the United States Postal Service. This letter will include instructions for requesting reconsideration of this decision. All Medicare-certified SNF non-compliance letters will be distributed through the United States Postal Service (USPS) and distributed electronically into the Certification and Survey Provider Enhanced Reports (CASPER) folders within the Quality Improvement and Evaluation System (QIES) for each SNF to access. This letter also includes the reason(s) for failing APU compliance. Instructions to download files in QIES may be found at https://www.qtso.com/mds30.html.

What is Reconsideration?

Reconsideration is a request for a review of the initial CMS compliance determination for a given SNF, for a given fiscal year (FY).

When Would a SNF Submit a Reconsideration Request?

SNFs may file for reconsideration if they believe the finding of non-compliance is in error, or they have evidence of the impact of extraordinary circumstances which prevented timely submission of data.

Important Note: Any exception or extension requests submitted for purposes of the SNF QRP will apply to that program only, and not to any other program CMS administers for SNFs, such as survey and certification. MDS requirements, including electronic submission, during Declared Public Health Emergencies can be found at FAQs K–5, K–6, and K–9 on the following link: http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/downloads/AllHazardsFAQs.pdf.

Reconsideration Request Process

To apply for reconsideration, the SNF must receive a CMS letter of non-compliance. A SNF disagreeing with the 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 distributed electronically using QIES. CMS will not accept any requests submitted after the thirty (30) days deadline.

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.

SNFs are required to submit their request to CMS via email with the subject line: “SNF QRP Reconsideration Request” and include the SNF CMS Certification Number (CCN) (e.g., SNF QRP Reconsideration Request, XXXXXX). The request must be sent to the following email address: SNFQRPReconsiderations@cms.hhs.gov.

The email request must contain the following information:

  • SNF CMS Certification Number (CCN);
  • SNF Name;
  • SNF Business Address
  • CEO or CEO-designated personnel contact information including name, telephone number, email address, and mailing address (the address must be a physical address, not a post office box);
  • CMS identified reason(s) for non-compliance from the non-compliance notification letter;
  • Information supporting the SNF belief that either 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 that fails to provide the necessary documentation along with the request for reconsideration. Supporting documentation may include any or all of the following:
  • Proof of submission
  • Email communications
  • Data submission reports from the Quality Improvement Evaluation System (QIES)
  • Proof of approved exception or extension for the reporting time frame
  • Copy of the CCN activation letter
  • Other documentation supporting the rationale for seeking reconsideration

IMPORTANT:

Never include protected health information (PHI), patient identifiable information (PII), or other Health Insurance Portability and Accountability Act (HIPAA) violations in the documentation being submitted to CMS for review. Submitting resident-level data or protected health information may be a violation of your facilities’ policies and procedures as well as violation of federal regulations (HIPAA).

Review Data Submissions

For FY 2019 payment determination, SNFs are required to submit data for the following quality measures:

  • NQF# 0678: Percent of Patients or Residents with Pressure Ulcers that are New or Worsened for the reporting period of January 1, 2017, through December 31, 2017
  • NQF# 0674: Application of Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay) for the reporting period of January 1, 2017, through December 31, 2017
  • NQF#2631: Application of Percent of Long- Term Care Hospital Patients with and Admission and Discharge Functional Assessment and a Care Plan that Addresses Function for the reporting period of January 1, 2017, through December 31, 2017

Please refer to the SNF Quality Reporting Program Data Submission Deadlines webpage for information on Data Collection Timeframes and Submission Deadlines

Reconsideration Request Process Timeline 

 Below is the estimated CMS reconsideration process timeline for FY 2019 payment determination:

  • June - July 2018 - CMS issues notices of non-compliance to SNFs that failed to meet quality reporting requirements
  • July - August 2018 - Reconsideration requests are due to CMS no later than thirty (30) days from the date on the notification of non-compliance distributed electronically into the CASPER folders in QIES
  • July - August 2018 - CMS provides an email acknowledgement within five (5) business days upon receipt of reconsideration request.
  • September 2018 - CMS notifies SNFs of the Agency’s decision on the reconsideration requests via letter from the USPS as well as distributed electronically into the CASPER folders in QIES. 

Filing an Appeal

SNFs 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.

Exception and Extension

Exception and Extension Requests Overview

CMS provides SNFs an opportunity to request an exception or extension from the program’s reporting requirements in the event they are unable to submit quality data due to extraordinary circumstances beyond their control. SNFs affected by a natural or man-made disaster or other extraordinary circumstances may request an exception or extension by filing a Request for Reconsideration Due to Disaster or Extraordinary Circumstance.

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

All SNFs 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 or extension to SNFs 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.

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

SNF CCN

SNF Business Name

SNF Business Address

CEO or CEO-designated personnel contact information including name, email address, telephone number, and physical mailing address

Description of the event (examples provided above) associated with the reason for requesting the exception or extension

A date when the SNF believes that it will again be able to submit SNF QRP data and a justification for the proposed date.

Any other documentation supporting the rationale for seeking reconsideration

Response from CMS

CMS will provide a written acknowledgement 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 USPS mail and email.

IMPORTANT:

Never include protected health information (PHI), patient identifiable information (PII), or other Health Insurance Portability and Accountability Act (HIPAA) violations in the documentation being submitted to CMS for review. Submitting resident-level data or protected health information may be a violation of your facilities’ policies and procedures as well as violation of federal regulations (HIPAA).

For More Information

For additional assistance, SNFs may submit questions related to the reconsideration or SNF QRP exception and extension request to: SNFQRPReconsiderations@cms.hhs.gov.

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