This Monday Minute will review the reality that the HHQRP and HQRP requirements were reinitiated with penalties as of July 1, 2020.

Good morning, everyone and welcome to our Monday Minute. Today I’d like to discuss with you the Quality Reporting Program requirements for both Home Health and Hospice. As far as the deadlines are concerned, what’s included in those and the penalties that will be assessed if you are not compliant.

It has been a very eye-opening situation in the last few months and discovering that many agencies did not realize that even though we are in the middle of a Public Health Emergency, that continues as of right now into January 2022, that the Home Health and Hospice Quality Reporting Program requirements were re initiated. July 1, 2020 the Quality Reporting Program requirements were reinstated. This means that for Home Health, they are monitoring that at least 90% of your OASIS transmissions are or consist of, I should say, 90% quality assessments, which is putting together a start of care to discharge or resumption of care to discharge so that they see a full quality episode.

If you do not meet that 90% you will be assessed a penalty in subsequent years of 2% against reimbursement. The Quality Reporting Program requirements, in this aspect for Home Health, runs from July 1 through June 30. It became apparent that agencies didn’t realize that this had been reinstated when they began to see reports in mid-2021. Some assessed a penalty because the agency had not met the 90% requirement that went back to July 1 of last year. You need to make sure that you are on top of this and primarily for Home Health. In order for you to avoid a penalty, you basically need to make sure that you are transmitting all OASIS that are completed for the patients, not just starts of care and recertifications,  but all the OASIS that are completed for patients. From a hospice standpoint you are required to have HIS transmitted within 30 days of completion at start of care and discharge. The 30-day completion requirement includes at least 90% of the HIS are transmitted timely, which means within that 30-day parameter.  There has been a significant change to the HIS penalty effective January 1, 2022. And that is that if you do not meet the 90% timely filing requirement for the HIS, you will be penalized 4% instead of 2% in subsequent years. The calculation for the HIS compliance is January to December, and so effective January 1, 2022 for the 2022 calendar year, if you’re not compliant, you will see a 4% reduction in payment in 2024.

Keep in mind that in addition to these penalties, for transmission requirements, even if you were to meet those requirements, there is also the requirement that you are compliant with HHCAHPS survey requirements or the CAHPS Hospice Survey requirement. You have to be compliant with submission of those in addition to the submission of OASIS and HIS. Please understand that even though we are in this Public Health Emergency still, the requirements for the Quality Reporting Transmission were reinstated July 1, 2020 and will continue to be calculated and penalties assessed moving forward.

We want to thank you all for participating today. Hope you have a fabulous week as we have turned the corner from Thanksgiving and head toward Christmas. I know it’s a very busy time of year, but I hope that you have time to continue to spend with your families. Also, make sure that you are focused in preparing for the things that you need to do so within your business in home health and hospice, and if there’s anything we can do for you, let us know.