On March 22, 2020, and as subsequently clarified on March 27, 2020, the Centers for Medicare and Medicaid Services (“CMS”) temporarily lifted the requirements for hospices to submit Hospice Item Set (“HIS”) data and hospice Consumer Assessment of Healthcare Providers and Systems (“CAHPS”) survey data.  Prior to CMS’s action, failure to comply with these data reporting requirements of the Hospice Quality Reporting Program (“HQRP”), absent an exception, resulted in a 2 percent reduction to a hospice’s annual Medicare payment update.

Specifically, CMS announced it has modified the 2019 and 2020 HQRP data submission requirements as follows:

  • 2019 Data Submission Requirements Are Optional. Deadlines for submission of data for the period of October 1, 2019 through December 31, 2019 are now optional.  This means that it is now optional to submit hospice CAHPS survey data collected during the fourth calendar quarter of 2019.  Normally, such data would have had to be submitted by May 13, 2020.
  • 2020 Data Submission Requirements Are Waived. Hospices no longer need to submit HIS data or CAHPS survey data for the period of January 1, 2020 through June 30, 2020.[1]  Normally, 90 percent of all HIS records had to be submitted within 30 days of the admission or discharge date, and CAHPS survey data had to be submitted on a quarterly basis on the second Wednesdays of February, May, August, and November.

In its March 22 announcement, CMS stated that it is relaxing these quality reporting requirements as temporary relief to the health care providers who are keeping the country safe during the COVID-19 outbreak.  “In granting these exceptions and extensions, CMS is supporting clinicians fighting Coronavirus on the front lines,” said CMS Administrator Seema Verma. “The Trump Administration is cutting bureaucratic red tape so the healthcare delivery system can direct its time and resources toward caring for patients.”

Because the data submission relief is only temporary, hospices if possible should consider continuing to use their current systems and vendors to collect HIS and CAHPS quality data.  Maintaining such continuity of quality data operations will position hospices well to resume HQRP data submission activities after CMS’s temporary relief comes to an end.

CMS also is relaxing certain reporting requirements for eligible clinicians under the Merit-Based Incentive Payment System (“MIPS”), for hospital quality reporting programs, and for a variety of post-acute care quality reporting programs.  CMS’s full March 22 announcement is available here, and its subsequent March 27 memorandum is available here.

The Husch Blackwell Hospice Team are problem-solvers, and we are here to provide you with support, guidance, ideas, and strategies in the face of this unprecedented pandemic. If you are having challenges related to the coronavirus, please let us advocate for you, develop materials to help you trouble-shoot, or otherwise be of assistance to you. We are here to serve.

[1] Note that CMS’s original announcement on March 22, 2020 states that hospices no longer need to submit CAHPS survey data for the period of January 1, 2020 through September 30, 2020.  However, CMS released a memorandum on March 27, 2020 clarifying that hospices no longer need to submit CAHPS survey data for the period of January 1, 2020 through June 30, 2020.  The original version of this COVID-19 Hospice How-To Series Article has been updated to reflect the latest information from CMS.