By Wendy Biddle, J.D.
An unexpected staffing change at a hospital does not excuse the failure to timely submit required data, and therefore subjected the hospital to a reduction in its market-based payment update pursuant to 42 C.F.R. Sec. 412.64(d)(2)(i) (St. Joseph’s Hospital v. National Government Services, Inc., PRRB Hearing, Dec. No. 2018-D16, Case No. 16-2080, January 24, 2018).
Background. St. Joseph’s Hospital is a small, 14-bed, acute care hospital in Elmira, New York, to which Medicare pays predetermined, standardized amounts for inpatient services under the inpatient prospective payment system (IPPS). Those standardized payment amounts are updated annually (the "market-basket update"). CMS requires each hospital submit quality of care data into an online system, QualityNet, in order to meet the Hospital Inpatient Quality Reporting (IQR) requirements for Medicare. Failure to submit required IQR data results in a one-fourth reduction of the hospital’s market basket update and excludes the hospital from participating in the value-based purchasing (VBP) program as added by Sec. 3001(a)(1) of the Patient Protection and Affordable Care Act (P.L. 111-148).
The sole employee who was responsible for submitting St. Joseph’s IQR data left employment prior to the February 1, 2016 reporting deadline. When another employee learned of the deadline, he attempted to log into the system but was unable to because his login information was inactive. As a result, the hospital was unable to submit the IQR data on time. Subsequently, CMS reduced St. Joseph’s market-basket update based on the hospital’s failure to submit aggregate initial patient population and sample size counts, as well as clinical measures by the prescribed deadlines. St. Joseph’s requested reconsideration, but CMS upheld the payment reduction. The hospital appealed to the Provider Reimbursement Review Board (PRRB).
PRRB decision. The PRRB concluded that the hospital did not follow CMS’ recommendations of having two security administrators who can enter the data in the system. In fact, St. Joseph’s did not have any security administrators after the sole security administrator left employment at the hospital, and therefore, no data could be submitted by the deadline. Because the hospital failed to submit the data required by the deadline, CMS reduced the market based update for FY 2017 and the PRRB concluded it was proper to do so.
Fiscal year ending 2017.
Companies: St. Joseph’s Hospital; National Government Services, Inc.
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