Health Reform WK-EDGE Facility’s APU dinged 2 percent for fields left blank during enrollment
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Monday, February 25, 2019

Facility’s APU dinged 2 percent for fields left blank during enrollment

By Leah S. Poniatowski, J.D.

Psychiatric hospital failed to confirm all data fields were complete during re-enrollment with new facility number despite numerous warnings, justifying reduction.

An in-patient psychiatric hospital in New Jersey had its annual percentage update (APU) for fiscal year 2017 reduced by 2 percent for failure to meet the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program requirements because the hospital did not verify its enrollment was complete, which caused the data not to be transmitted to CMS by the deadline, a Provider Reimbursement Review Board determined (Christian Healthcare Center d/b/a Ramapo Ridge v. Novitas Solutions, Inc., PRRB Hearing, Dec. 2019-D9, Case No. 17-1958, February 14, 2019).

Background. Ramapo Ridge, a 58-bed in-patient psychiatric hospital, and similar facilities are eligible for a full APU by participating in the quality reporting program pursuant to 42 U.S.C. § 1395ww(s)(4), as amended by §§3401(f) and 10322(a) of the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148). CMS issued a final rule in 2014 requiring facilities such as Ramapo Ridge to report data on influenza vaccination coverage of the healthcare personnel, tying the reporting to fiscal year 2017 payment determinations. Thus, in-patient psychiatric facilities must report influenza vaccination data for the 2015-2016 influenza season through the National Healthcare Safety Network (NHSN) by June 15, 2016 in order to meet the IPFQR Program requirements. The NHSN made available several resources on how to properly report the data with respect to the IPFQR Program.

Registration issues. In March 2016, Ramapo Ridge was notified that it had not yet registered its personnel influenza vaccine data through the NHSN and that failure to register by the deadline jeopardized its receipt of the full APU for fiscal year 2017. Ramapo Ridge had completed the data submission and confirmed in May that the data were in the system. A month later, Ramapo Ridge reached out to a NHSN contact about the notice, learning that the facility number under which it had completed the enrollment was improper and that Ramapo Ridge would need to re-enroll under a corrected facility number. The hospital was provided contact information of someone to help with the re-enrollment and the caveat that the hospital should ensure that the correct CMS Certification Number be entered in order for the data to be reported to CMS. On June 13, 2016, Ramapo Ridge obtained the correct facility number and the following day, one day before the deadline, logged into the NHSN with the new Facility ID, entering the data vis-a-vis its personnel influenza vaccines.

In September 2016, CMS informed Ramapo Ridge that its data for the IPFQR Program had not been submitted and, consequently, its APU for 2017 would be reduced by 2 percent. CMS declined to reconsider the determination. The hospital contacted the NHSN, learning in March 2017 that the CMS Certification Number field and the number effective date fields had been left blank, thus the data failed to be sent to CMS. Ramapo Ridge stated that it assumed the NHSN contractor who helped the hospital re-enroll would have entered that information. The hospital filed the present petition to the Provider Reimbursement Review Board.

Decision. The Board stated that it was sympathetic to Ramapo Ridge’s circumstances, but that there was ample documentation that NHSN enrollment is the obligation of the facility. One of the materials provided to the hospital, the "Facility Enrollment & Set-Up Checklist," instructed the hospital to verify and update its CMS Certification Number, even cautioning "Please be sure to double- and triple-check this number!" Additionally, Ramapo Ridge was directly advised to verify that its number be entered into the NHSN. The Board observed that the hospital was capable of logging in and entering the vaccine data. Because the hospital failed to enter the required information in the NHSN as had been instructed, the hospital failed to comply with the requirements, and CMS’ APU reduction was correct.

Cost report period ending fiscal year 2017.

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