News Alert: CMS Notifies IRFs of Non-Compliance with Quality Reporting Requirements: How to Respond

Facilities that received a notice of non-compliance and believe the notice is in error must respond by Aug. 7, 2018

The Centers for Medicare & Medicaid Services (CMS) announced on July 6 that notifications to facilities that were determined to be out of compliance with the Inpatient Rehabilitation Facility (IRF) Quality Reporting Program (QRP) requirements for 2017 would be mailed and placed into the facilities’ Certification And Survey Provider-Enhanced Reports (CASPER) folders.

Facilities that received a notice of non-compliance and believe the notice is in error have only until Aug. 7, 2018 to submit a request for reconsideration. Note that the date in letters and the date in the posted notice may differ slightly from what is noted on the CMS web page regarding reconsiderations, so we advise that you use the Aug. 7 date.

The notices arriving at IRFs in our client base triggered calls for assistance with this issue. To assist other IRFs, we have prepared this article to provide you with the steps to take in order to request a reconsideration.

How Were IRFs Notified?

Notifications should occur in two ways:

  • They were placed in facilities’ CASPER folders via the Quality Improvement and Evaluation System (QIES) on July 9; and
  • They were also mailed to the current authorized official(s) at the IRFs (letters we have seen were dated a few days later).

If you are uncertain if you received a letter due to processing time for mail, check your CASPER folder today!

What Triggers the Notice?

IRFs are required to submit quality data both through the IRF-PAI that is transmitted to the QIES system and to the Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN). Both sets of data have time requirements and requirements for completion of the data elements. Failure to meet time or data content mandates will result in a determination of non-compliance. The period of time involved for this data set was 2017.

What’s the Impact?

IRFs that fail to meet the reporting requirements are subject to a 2 percent reduction in the 2019 fiscal-year annual increase factor, which impacts reimbursement for all Medicare fee-for-service (FFS) claims during that period.

Because of this impact, we strongly urge IRFs that believe they comply to request a reconsideration if it appears that at least some of these determinations were made in error.

How Do We Request a Reconsideration?

  • Reconsideration requests are only accepted via email at IRFQRPreconsiderations@cms.hhs.gov.
  • Questions about the process and about what documentation is acceptable can also be addressed to this email account.
  • Submit your request on or before Aug. 7, 2018.
  • The following detail has been copied directly from the CMS website to assist you including the correct data:

Reconsideration Request Process

To apply for reconsideration, the IRF must receive a CMS letter of non-compliance. An IRF 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) day deadline.

Create a 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.

IRFs are required to submit their request to CMS via email with the subject line: “IRF ACA 3004 Reconsideration Request” and include the IRF CMS Certification Number (CCN) (e.g., IRF ACA 3004 Reconsideration Request, XXXXXX). The request must be sent to the following email address: IRFQRPReconsiderations@cms.hhs.gov.

The email request must contain the following information:

  • IRF CMS Certification Number (CCN)
  • IRF Business Name
  • IRF Business Address
  • CEO or CEO-designated representative contact information, including: name, email address, telephone number, and physical mailing address
  • CMS identified reason(s) for non-compliance from the non-compliance notification letter
  • Information supporting the IRF 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)
  • Data submission reports from the National Healthcare Safety Network (NHSN)
  • 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 patient information (i.e. protected health information (PHI), patient identifiable information (PII), or other Health Insurance Portability and Accountability Act (HIPAA) violation) in the documentation being submitted to CMS for review.  Submitting patient-level data or protected health information may be a violation of your facilities’ policies and procedures as well as violation of federal regulations (HIPAA).

What’s the Bottom Line?

IRFs need to investigate any determinations related to compliance, whether they were associated with reporting requirements or claims denials, as there is often good evidence to support a reversal of a negative decision.

Program Note

Listen to Angela Phillips report this story on Monitor Monday July 23, 10-10:30 a.m. PT.

 

Comment on this article

Print Friendly, PDF & Email
Facebook
Twitter
LinkedIn

Angela Phillips, PT

Angela M. Phillips, PT, is President & Chief Executive Officer of Images & Associates. A graduate of the University of Pennsylvania, School of Allied Health Professions, she has almost 45 years of experience as a consultant, healthcare executive, hospital administrator, educator, and clinician. Ms. Phillips is one of the nation’s leading consultants assisting Inpatient Rehabilitation Facilities in operating effectively under the Medicare Prospective Payment System (PPS) and in addressing key issues related to compliance.

Related Stories

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

Pediatric SDoH: An Essential Guide to Accurate Coding and Reporting

Pediatric SDoH: An Essential Guide to Accurate Coding and Reporting

This webcast, presented by Tiffany Ferguson, LMSW, CMAC, ACM, addresses the critical gap in Social Determinants of Health (SDoH) reporting for pediatric populations. While SDoH efforts often focus on adults, this session emphasizes the unique needs of children. Attendees will gain insights into the current state of SDoH, new pediatric Z-codes, and the importance of interdisciplinary collaboration. By understanding and applying pediatric-specific SDoH factors, healthcare professionals can improve data capture, compliance, and care outcomes. This webcast is essential for those looking to enhance their approach to pediatric SDoH reporting and coding.

August 8, 2024
Oncology and E/M Services: Compliance, Medical Necessity, and Reimbursement

Oncology and E/M Services: Compliance, Medical Necessity, and Reimbursement

Join Becky Jacobsen, BSN, RN, MBS, CCS-P, CPC, CPEDC, CBCS, CEMC, VP of CDM, for a webcast addressing oncology service coding challenges. Learn to navigate coding for infusions and injections alongside Evaluation and Management (E/M) services, ensuring compliance and accurate reimbursement. Gain insights into documenting E/M services for oncology patients and determining medical necessity. This webcast is essential to optimize coding practices, maintain compliance, and maximize revenue in oncology care.

July 30, 2024
The Inpatient Admission Order: Master the Who, When, and How

The Inpatient Admission Order: Master the Who, When, and How

During this webcast Dr. Ronald Hirsch delves into the inpatient admission order process including when to get it, when it becomes effective, its impact on billing and payment, who can write it, how to cancel it, the effects on the beneficiary, and more. You’ll leave with a clear understanding of inpatient orders and guidelines for handling improper orders that you can implement immediately.

June 20, 2024
Navigating AI in Healthcare Revenue Cycle: Maximizing Efficiency, Minimizing Risks

Navigating AI in Healthcare Revenue Cycle: Maximizing Efficiency, Minimizing Risks

Michelle Wieczorek explores challenges, strategies, and best practices to AI implementation and ongoing monitoring in the middle revenue cycle through real-world use cases. She addresses critical issues such as the validation of AI algorithms, the importance of human validation in machine learning, and the delineation of responsibilities between buyers and vendors.

May 21, 2024
Comprehensive Inpatient Clinical Documentation Integrity: From Foundations to Advanced Strategies

Comprehensive Inpatient Clinical Documentation Integrity: From Foundations to Advanced Strategies

Optimize your inpatient clinical documentation and gain comprehensive knowledge from foundational practices to advanced technologies, ensuring improved patient care and organizational and financial success. This webcast bundle provides a holistic approach to CDI, empowering you to implement best practices from the ground up and leverage advanced strategies for superior results. Participants will gain actionable insights to improve documentation quality, patient care, compliance, and financial outcomes.

June 26, 2024
Advanced Inpatient Clinical Documentation Integrity: Harnessing Technology, Analytics, and Compliance

Advanced Inpatient Clinical Documentation Integrity: Harnessing Technology, Analytics, and Compliance

Join expert Angela Comfort, MBA, RHIA, CDIP, CCS, CCS-P., as she helps you navigate advanced inpatient CDI technologies, regulatory changes, and system interoperability. Angela will provide actionable strategies for integrating AI and predictive analytics into CDI practices, ensuring seamless system interoperability, and maintaining compliance with evolving regulations. Attendees will learn to select and implement advanced EHR systems and CDI software, leverage data analytics to enhance documentation accuracy, and stay audit-ready with the latest compliance updates. Real-world case studies and practical tools will empower you to drive continuous improvement in CDI, improve patient outcomes, and enhance organizational efficiency. Don’t miss this opportunity to advance your CDI practices and stay ahead in this dynamic field.

July 11, 2024
Foundations of Inpatient Clinical Documentation Integrity: Enhancing Accuracy and Compliance

Foundations of Inpatient Clinical Documentation Integrity: Enhancing Accuracy and Compliance

Join expert Angela Comfort, MBA, RHIA, CDIP, CCS, CCS-P, for an insightful webcast on improving inpatient clinical documentation integrity (CDI). Inaccurate documentation can lead to misdiagnosis, improper treatment, and compromised patient safety. High workloads, lack of standardized practices, and outdated EHR systems contribute to these issues, affecting care quality and financial outcomes. Angela will offer practical strategies and tools to enhance accuracy, consistency, and timeliness in documentation. Attendees will learn to use standardized templates, checklists, and advanced EHR systems, while staying compliant with regulations. Improve patient care, ensure accurate billing, and reduce audit risks with actionable insights from this essential webcast.

June 26, 2024
Mastering E/M Coding: Navigating the Evolving Landscape

Mastering E/M Coding: Navigating the Evolving Landscape

Join industry expert, Kathy Pride, RHIT, CPC, CPMA, CCS-P, for an in-depth exploration of Evaluation and Management (E/M) coding, tailored for healthcare professionals navigating recent guideline changes. Dive into advanced topics beyond mere code selection, including shared visits, criteria for selecting E/M levels, and documentation best practices. Gain clarity on complex guideline terminology and ensure compliance with regulatory standards. This comprehensive session is essential for coders, auditors, educators, and practitioners seeking to enhance their proficiency in E/M coding and maximize revenue capture.

June 19, 2024

Trending News

Get 15% OFF on all educational webcasts at RACmonitor with code JULYFOURTH24 until July 4, 2024—start learning today!

Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →