By Patricia K. Ruiz, J.D.
A two percentage point reduction in Conway Regional Rehabilitation Hospital’s market basket update was warranted, as the inpatient rehabilitation facility (IRF) failed to submit data required under the IRF quality reporting program as required. According to the Provider Reimbursement Review Board (PRRB), the IRF failed to provide data until almost seven months after the reporting deadline (Conway Regional Rehabilitation Hospital (Conway, Ark.) v. Novitas Solutions, Inc., PRRB Hearing, Dec. No. 2018-D42, Case No. 17-1167, October 4, 2017).
Background. Conway’s Medicare Contractor notified it of CMS’s determination that the provider failed to meet IRF requirements under the QRP for fiscal year (FY) 2017, resulting in a two percentage point payment reduction in Conway’s FY 2017 annual increase factor. Specifically, CMS cited Conway’s failure to submit QRP data for the Catheter-Associated Urinary Tract Infection (CAUTI) Outcome Measure for the third quarter of calendar year 2015. On request for reconsideration, CMS upheld its decision, and Conway timely appealed to the PRRB.
Market basket update. Medicare pays rehabilitation facilities under the IRF prospective payment system (IRF PPS), under which Medicare pays predetermined, standardized amounts per discharge, subject to certain payment adjustments. The payment amounts are increased each year when a market basket update is applied to account for increases in operating costs. The Patient Protection and Affordable Care Act (ACA) (P.L. 111-148) established the IRF QRP, which requires rehabilitation facilities to submit quality of care data. CMS applies a one-time two percentage point reduction to the market basket update for IRFs that fail to report the required quality data. The submission of CAUTI quality data triggers such a reduction.
Missing data for July 2015. Upon close examination of Conway’s National Health Safety Network (NHSN) printout, the PRRB found that Conway failed to submit its monthly plan for CAUTI for July 2015. The PRRB also found that Conway’s Certification and Survey Provider Enhanced Reporting (CASPER) shows that CAUTI data was successfully reported for August and September 2015, but not for July 2015. The CUATI plan for July 2015 was not added until August 9, 2016, well after the reporting deadline of February 15, 2016. The PRRB noted that the NHSN website contains a resource page to assist providers in reporting and checking that submitted data is complete. Thus, the PRRB concluded that the two percentage point reduction in Conway’s market basket update for FY 2017 is proper.
Cost reporting period ending 2017.
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