Hello everyone, welcome to our Monday Minute. Today I’d like to discuss with you the Hospice Quality Reporting Program and some of the details behind the penalty that you could possibly receive when your hospice is not compliant.

There are two portions to the Hospice Quality Reporting Program. One is related to the CAHPS Hospice Survey participation, and the other is related to the HIS transmission requirement. You’re required to have at least 90% of your HIS transmissions to be within the 30-day limit, 30 days from the date that that assessment is actually completed, whether it be admission or discharge.

The CAHPS Hospice Survey requirement includes that all hospices that have seen more than 50 decedents in any given year are required, in the following or subsequent years, to participate in the survey program. If you feel that or know that you have seen fewer than 50 decedents in any given calendar year, you may request an exemption from participation in the CAHPS survey program and must do so through actually filing an exemption form.

In the details of this Minute today we will provide you with a link to that exemption form and you do have this entire year to file that exemption form for 2021. Once we get to the end of 2022, they will calculate and you will get a letter based on your compliance from 2021. So last year 2021, at the end of 2021, hospices began to receive letters if they were not compliant in 2020.  The good news is they completely got rid of participation from January through June of 2020, and only counted or made calculations for the program for July through December. Based on July through December, if you were found to be non compliant, you received a letter that said your payments in 2022 will be reduced by 2%. They have now issued memos to state that there is going to be a reopening opportunity in March of 2022.  You will receive a letter from your Medicare MAC giving you a 30-day window in which you must submit the reopening request with details as to why the Public Health Emergency impacted your noncompliance with the Hospice Quality Reporting Program in the second half of 2020.

They have been very clear that they will not consider anything related to January through June, because they’re only looking at data for July through December. Make sure that someone is paying attention to the receipt of that letter from your MAC and that if you do need to request an exemption or a reopening of that decision from 2020, that you do so.

For the calendar year 2022 they are going to be calculating, of course, your 90% compliance with HIS, as well as the CAHPS Hospice Survey requirements. The bad part is or the really bad part is that the penalty, if you are not compliant this year, will impact your payments in 2024 and that payment penalty has been raised to 4%. It is no longer 2%. So you need to make sure that you are compliant and that someone within your organization is monitoring that. Within the details of this Minute today we will provide the link to the Hospice Quality Reporting Program portion of the CMS website as well as the exemption form that I mentioned earlier.

If you need any further assistance with this information, please let us know or contact your state or national home care or hospice association. Thank you all for continuing to be on the frontlines during the spiraling Public Health Emergency. We pray for your safety. Thank you and have a fabulous week!


CAHPS Hospice Survey Exemption Form


Don’t miss our QAPI – Hospice Webinar coming this February 24, 2022!