Health Reform WK-EDGE LTCH assessed penalty after entering wrong location code
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Friday, January 25, 2019

LTCH assessed penalty after entering wrong location code

By Sheila Lynch-Afryl, J.D., M.A.

A long-term care hospital (LTCH) failed to meet LTCH quality reporting program requirements when its submissions lacked the required location codes, resulting in a 2 percent penalty reduction.

A long-term care hospital (LTCH) was properly assessed a 2 percent penalty reduction in fiscal year (FY) 2017 because it failed to meet the requirements of the LTCH quality reporting program (QRP). In 2015, certain QRP submissions lacked the required location code; as a result, the LTCH failed to submit the data in a form and manner, and at a time, specified by the Secretary (Post Acute Medical Specialty Hospital of Texarkana North v. Novitas Solutions, Inc., PRRB Hearing, Dec. No. 2018-D47, Case No. 17-1018, September 6, 2018).

Section 3004(a) of the Patient Protection and Affordable Care Act of 2010 (ACA) (P.L. 111-148) amended Soc. Sec. Act §1886(m)(5)(C) to establish the LTCH QRP. Under the LTCH QRP, an LTCH 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. §412.560). LTCHs submit certain quality data to the Centers for Disease Control and Prevention’s National Healthcare Safety Network (NHSN) system, including the Facility-Wide Inpatient Hospital-onset Clostridium difficile Infection Outcome Measure (CDI). However, the LTCH failed to enter the proper location code when it uploaded portions of its.

The LTCH argued that because it operates under only one provider number, the location code did not affect the availability of data in NHSN. While the LTCH submitted the CDI data to NHSN by the applicable deadlines, it conceded that the wrong location identifier was used when it submitted some of the CDI data for quarters 2 and 3 of FY 2015. Therefore, the required LTCH QRP data was not submitted in the form and manner, and at the time, specified by the Secretary.

Cost reporting period ending September 30, 2017.

Companies: Post Acute Medical Specialty Hospital of Texarkana North; Novitas Solutions, Inc.

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