The Centers for Medicare & Medicaid Services (CMS) is proposing targeted changes to the Long-Term Care Hospital (LTCH) Quality Reporting Program (QRP) in the fiscal year (FY) 2026 Inpatient Prospective Payment System (IPPS) Proposed Rule.
These updates are designed to reduce reporting burden, eliminate outdated or redundant measures, and pave the way for future digital innovation in post-acute care quality reporting.
While more modest than inpatient updates, these proposals are significant for LTCH administrators, health information management (HIM) leaders, and quality professionals who manage standardized assessment data and ensure compliance with the CMS evolving quality framework.
What’s Being Removed in FY 2026
CMS proposes to remove five data items from the LTCH Continuity Assessment Record and Evaluation (CARE) Data Set, particularly in cases in which the patient has expired during their LTCH stay. These items were deemed duplicative or of limited analytical value.
In addition, four Social Determinants of Health (SDOH) standardized patient assessment data elements are proposed for removal. CMS noted that these data points, while important for equity analysis, are either collected inconsistently across settings or lack the standardization required for actionable use in the LTCH QRP context.
Key takeaway: This effort reflects the CMS intent to streamline data requirements and reduce reporting fatigue for LTCHs without compromising quality tracking.
Refining the Reconsideration Process
CMS is proposing updates to the reconsideration request process for the LTCH QRP. This policy clarifies how LTCHs can appeal determinations of non-compliance with quality reporting requirements, ensuring a more structured and equitable process.
While only expected to add four administrative hours across all LTCHs nationwide, the proposed change ensures greater transparency and standardization in how reconsiderations are reviewed and resolved.
Requests for Information (RFIs): Shaping the Future of LTCH Quality Reporting
CMS is also using the proposed rule to solicit stakeholder feedback through three key Requests for Information (RFIs):
- Future Quality Measure Concepts for LTCHs
CMS is interested in identifying new outcome measures that reflect modern care delivery and long-term recovery in complex, high-acuity patients. This could include measures tied to patient function, care transitions, or caregiver engagement. - Assessment Data Submission Deadlines
CMS is considering revisions to the deadlines for submitting patient assessment data to improve timeliness, reduce reporting delays, and better align with other post-acute care settings. - Advancing Digital Quality Measurement (dQM)
CMS seeks input on how to implement digital quality measurement in the LTCH setting, including the use of Fast Healthcare Interoperability Resources (FHIR®) and automated data capture. This is part of a broader CMS strategy to reduce manual reporting and promote interoperability across the healthcare continuum.
Industry Implication: Providers are encouraged to share their input on these RFIs, which will likely shape the next phase of QRP modernization.
Estimated Burden Impact
- FY 2026: +4 hours and +$187.60 total nationwide (from reconsideration policy updates)
- FY 2028 and beyond: –2,633 reporting hours and –$180,016 in reporting costs due to data element removals and updated burden estimates
This reflects the CMS aim to streamline quality reporting without sacrificing outcome measurement integrity.
Conclusion
The FY 2026 IPPS Proposed Rule demonstrates the CMS continued effort to align the LTCH QRP with national quality goals while reducing administrative burden on post-acute providers. These changes combined with strategic RFIs signal that digital transformation and data simplification are front and center for long-term care quality oversight.
LTCHs are encouraged to undertake the following:
- Review data collection workflows for CARE Data Set items and SDOH elements;
- Prepare for reconsideration process clarifications; and
- Respond to the CMS RFIs on digital measurement, new quality metrics, and reporting deadlines.
Submit comments by June 10, 2025, referencing file code CMS-1833-P
To read the full proposed rule or submit feedback, visit https://www.regulations.gov and search for CMS-1833-P.
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