COVID-19: CMS Issues SNF QRP / SNF VBP Guidance Memo (3/20)

By CMS - March 27, 2020

DATE: March 27, 2020

TO: MLN Connects Newsletter and Other Program-Specific Listserv Recipients

FROM: [Program-Specific Listservs, Partner Listservs (e.g., NHSN), ESRD Networks, CMS Emergency web page]

SUBJECT: Exceptions and Extensions for Quality Reporting Requirements for Acute Care Hospitals, PPS-Exempt Cancer Hospitals, Inpatient Psychiatric Facilities, Skilled Nursing Facilities, Home Health Agencies, Hospices, Inpatient Rehabilitation Facilities, Long-Term Care Hospitals, Ambulatory Surgical Centers, Renal Dialysis Facilities, and MIPS Eligible Clinicians Affected by COVID-19

 

The Centers for Medicare & Medicaid Services (CMS) is granting exceptions1 under certain Medicare quality reporting and value-based purchasing programs for acute care hospitals, Prospective Payment System (PPS)-exempt cancer hospitals, inpatient psychiatric facilities, skilled nursing facilities, home health agencies, hospices, inpatient rehabilitation facilities, longterm care hospitals, ambulatory surgical centers, renal dialysis facilities, and Merit-based Incentive Payment System (MIPS) eligible clinicians for all providers and suppliers participating in the programs described below across the United States and its territories in response to the 2019 Novel Coronavirus (COVID-19) pandemic.

 

On March 22, 2020, CMS announced relief for clinicians, providers, hospitals and facilities participating in quality reporting programs in response to COVID-19.2 This memorandum supplements and provides additional guidance to health care providers with regard to the announcement. The scope and duration of the exceptions under each Medicare quality reporting program and value-based purchasing program are described below. CMS is granting exceptions and extensions for certain deadlines to assist these health care providers while they direct their resources toward caring for their patients and ensuring the health and safety of patients and staff. In some instances, these exceptions and extensions are granted because the data collected may be greatly impacted by the response to COVID-19 and therefore should not be considered in the quality reporting program. CMS is closely monitoring the situation for potential adjustments and will update exception lists, exempted reporting periods, and submission deadlines accordingly as events occur.

 

Home Health Agencies (HHAs), Hospices, Inpatient Rehabilitation Facilities (IRFs), LongTerm Care Hospitals (LTCHs), and Skilled Nursing Facilities (SNFs)

CMS is granting an exception to the Quality Reporting Program (QRP) reporting requirements for all HHAs, Hospices, IRFs, LTCHs and SNFs. In accordance with 42 C.F.R. 412.560(c), 412.634(c), 413.360(c), 484.245(c), these providers are excepted from the reporting of data on measures, Consumer Assessment of Healthcare Providers and Systems (CAHPS) surveys, and standardized patient assessment data required under these programs for the post-acute care (PAC) quality reporting programs for calendar years (CYs) 2019 and 2020 for the following quarters specific to each program:

  • SNFs–Skilled Nursing Facility QRP
  • October 1, 2019–December 31, 2019 (Q4 2019)
  • January 1, 2020–March 31, 2020 (Q1 2020)
  • April 1, 2020–June 30, 2020 (Q2 2020)

 

CMS finalized the SNF VBP Program’s Extraordinary Circumstances Exception (ECE) Policy in the FY 2019 SNF PPS final rule (83 FR 39280 through 39281). In accordance with § 413.338(d)(4)(iv) for the Skilled Nursing Facility Value-Based Purchasing (SNF VBP) Program, CMS will exclude qualifying claims from the claims-based SNF 30-Day All-Cause Readmission Measure (SNFRM; NQF #2510) calculation for the following periods:

  • January 1, 2020–March 31, 2020 (Q1 2020)
  • April 1, 2020–June 30, 2020 (Q2 2020)

 

PAC QRP Extraordinary Circumstances Exception Request Information For further information about exceptions, view the program-specific web pages:

SNF Quality Reporting Reconsideration and Exception & Extension or email questions toSNFQRPReconsiderations@cms.hhs.gov