QRP & VBP Reporting Relief for Post Acute Care providers Is a Mixed Bag

Members | March 24, 2020 | by Nicole Fallon

CMS announced it will reduce the data collection and reporting burden on providers. While reporting relief has been provided for quality reporting programs, many of these activities will likely continue for other purposes.

CMS announced it will reduce the data collection and reporting burden on providers. While reporting relief has been provided for quality reporting programs, many of these activities will likely continue for other purposes. 

The CMS announcement explicitly says that all April and May data submission deadlines for quality reporting programs are now optional. In addition, January 1 - June 30, 2020 data will not be used to calculate performance for the various quality reporting and value-based payment programs.

Skilled Nursing Facilities

For Skilled Nursing Facilities(SNFs), this relief covers two programs: 1) the SNF Quality Reporting Program (SNF QRP), which cuts SNF Medicare Fee For Service(FFS) rates by 2% for failure to adequately report MDS data used in calculating identified quality measures for the program; and 2) the SNF Value-Based Purchasing Program (SNF VBP), which determines SNF performance on a 30-day All Cause Readmission Measure using Medicare FFS claims data and adjusts SNF Medicare FFS rates based upon that performance.

Specifically, for the purposes of the QRP, CMS has said SNFs don’t need to report MDS-based data for admissions/discharges between October 1 – December 31, 2019 (previously due May 15, 2020).  However, CMS notes that if this data is submitted for Q4 2019 it will be used to calculate the 2019 performance, which will impact a SNF’s FY2021 Medicare FFS rates. The reality is it is likely that many SNFs have submitted some portion of this MDS data already. So the question for each organization is if they wish to make corrections before the May 15 deadline.

CMS also told SNFs they no longer need to submit MDS data for January 1 – June 30, 2020 for the purposes of complying with the SNF QRP.  This relief aligns nicely with the 1135 waiver that allows SNFs more flexibility in meeting the MDS assessment and transmission timeframes established under 42 CFR 483.20.  However, SNFs should keep in mind that completing MDS assessments are still a critical function for establishing payment rates under the Patient Driven Payment Model (PDPM) and for determining resident needs.  

For SNF VBP, CMS will exclude January 1 – June 30, 2020 claims data from its calculation of the SNF 30-day All-Cause Readmission Measure calculation. What is not clear is if FY2022 SNF VBP rate adjustments will be calculated using only October 1 – Dec. 31, 2019 and July – September 2020 readmissions data. If this is the case, it is also unclear and the potential effects of this shorter performance period on a SNF’s performance and corresponding rate adjustment.

Unlike the physician Quality Payment Program, for whom CMS clearly states that physicians will receive a “neutral payment adjustment for the 2021 MIPS payment year,” there is no such reassurance in the guidance for SNFs or other post acute care providers. LeadingAge will seek further clarification on many of the questions highlighted here including how CMS will approach determining SNF Medicare FFS rates for FY2021 without complete data.

Finally, it should be noted that this announcement did not include relief from reporting Payroll Based Journal data for January 1 – March 31, 2020, which is still due on May 15, 2020.

Home Health and Hospice Quality Reporting Programs

Home health and hospice providers are not required to:

  • Submit Q4 2019 (October 1 – December 31, 2019) data for the purposes of complying with the reporting requirements for the Home Health or Hospice Quality Reporting Program.  However, if this data is submitted, CMS will use it to calculate 2019 performance and payment for the QRP. This relief aligns nicely with the 1135 waiver that allows Home Health agencies more flexibility in meeting the OASIS transmission timeframes.
  • Submit Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey data for January 1 – September 30, 2020 to CMS.

While on its face the guidance appears to offer some relief for providers, in reality providers will need to continue completing these important assessments as they are used for other important purposes such as determining payment. Nonetheless, this guidance does remove one worry for providers if they aren’t able to meet previously prescribed reporting schedules. LeadingAge will continue to pursue clarification and further relief for providers.