Health Reform WK-EDGE Facility fails to report on flu vaccine among workers, assessed penalty
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Tuesday, October 2, 2018

Facility fails to report on flu vaccine among workers, assessed penalty

By Sheila Lynch-Afryl, J.D., M.A.

An inpatient rehabilitation unit was properly assessed a payment reduction for fiscal year (FY) 2017 because it failed to report Influenza Vaccination Coverage Among Healthcare Personnel data for the reporting period of October 1, 2015 through March 31, 2016, as required under the inpatient rehabilitation facility (IRF) quality reporting program (QRP) (Garden CityHospital v. Wisconsin Physicians Service, PRRB Hearing, Dec. No. 2018-D44, Case No. 17-0196, July 27, 2018).

Sec. 3004(b) of the Patient Protection and Affordable Care Act of 2010 (ACA) (P.L. 111-148) amended Soc. Sec. Act §1886(j)(7) to establish the IRF QRP. Under the IRF QRP, an IRF that fails to submit quality of care data "in a form and manner, and at a time, specified by the Secretary" receives a 2 percent reduction in its fee schedule increase factor (see 42 C.F.R. §412.634). CMS finalized the Influenza Vaccination Coverage Among Healthcare Personnel measure in the FY 2014 IRF Final rule (78 FR 47860, August 6, 2013); data collection for this measure is approximately six months instead of the usual 12 months for other measures.

The IRF argued that it submitted its quality data in compliance with the regulatory standards. However, an email from CMS and a notice from the IRF’s Certification and Survey Provider Enhanced Reports (CASPER) folder dated July 7, 2016, specified that the IRF was noncompliant because it failed to submit Influenza Vaccination Coverage Among Healthcare Personnel data. Even though the IRF claimed that it was not familiar with this folder, it had access to this letter in its CASPER folder.

Cost reporting period ending September 30, 2017.

Companies: Garden City Hospital; Wisconsin Physicians Service

AdministrativeDecisions: AgencyDecisions AgencyNews InpatientFacilityNews MedicarePartANews QualityNews

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