SNF QRP Non-Compliance Notices Available, Reconsideration Requests due Aug. 18

Regulation | July 15, 2020 | by Nicole Fallon

CMS reported Monday, July 13, that it had distributed notifications to skilled nursing facilities (SNF) determined to be out of compliance with the SNF Quality Reporting Program (QRP) requirements for Calendar Year 2019, impacting FY2021 SNF payments.

These letters notifying providers of noncompliance with QRP are distributed to SNFs in at least one of three possible ways: 1) through the Medicare Administrative Contractors (MACs); 2) placed in a provider’s CASPER folders in QIES; and/or a 3) Via U.S. Postal Service.  Providers deemed noncompliant will see their Medicare Fee For Service rates reduced 2% beginning October 1, 2020. If a provider receives a notification of noncompliance, they can choose to request reconsideration. The instructions for seeking reconsideration are detailed in the letter of non-compliance that you received or by going to the SNF QRP website and the section on reconsiderations.

Reconsideration requests are to be submitted to:   no later than 11:59 p.m. on August 18, 2020.

SNFs may recall that back in March 2020, CMS waived the SNF QRP reporting requirements for 4th quarter of 2019 (between October 1 – December 31, 2019) and the first two quarters of 2020 (January 1-June 30, 2020) as part of the response to the coronavirus. At the time, CMS noted that if the data was submitted for Q4 2019 it would be used to calculate a SNF’s 2019 QRP performance, which impacts a SNF’s FY2021 Medicare FFS rates. The reality is it is likely that many SNFs submitted some portion of this MDS data. This reporting waiver has ended and members are reminded that as of July 1, 2020, SNFs are expected to again report their quality data via their MDS submissions for Quarter 3 (July 1 – September 30, 2020).

CMS has indicated it “will analyze the data for each program recognizing that the COVID-19 public health emergency (PHE) remains in effect and could impact the quality data submitted. CMS will closely monitor the situation for public reporting of the data and provide any updates.” LeadingAge will continue to advocate to CMS our concerns about the potential for these data to be skewed as a result of the coronavirus and that skewed data impact on rates.