Health Reform WK-EDGE Quality data reporting required, even for ‘no event’ months
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Tuesday, October 25, 2016

Quality data reporting required, even for ‘no event’ months

By Kayla R. Bryant, J.D.

A hospital’s failure to meet the requirements of the long-term care hospital (LTCH) quality reporting program (QRP) properly resulted in a 2 percent reduction in the annual payment update. The Provider Reimbursement Review Board (PRRB) found that a CMS contractor was justified in imposing this reduction on Texas Specialty Hospital of Lubbock (Texas Specialty) after the hospital failed to submit a full year of data for two quality measures (Texas Specialty Hospital of Lubbock (Lubbock, Texas) v. Novitas Solutions, Inc., PRRB Hearing, Dec. No. 2016-D24, Case No. 15-1975, November 13, 2015).

Quality reporting program. The LTCH QRP, established by section 3004(a) of the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148) requires certain hospitals to submit data to the Center for Disease Control and Prevention’s (CDC) National Health Safety Network (NHSN) on a quarterly basis. The three data requirements were:

  • percent of residents with pressure ulcers (new or worsened);
  • catheter-associated urinary tract infections (CAUTI); and
  • central line catheter-associated bloodstream infections (CLABSI).

Texas Specialty acknowledged that it did not submit information for Q1-Q3 of 2013 CAUTI and CLABSI data by the deadlines. However, the hospital claimed that from March through September, no incidents of these infection occurred, and it reasoned that there was no requirement to submit data if there was nothing to report because the process is not clearly defined.

The PRRB disagreed, looking to 42 U.S.C. §1395ww(m)(5) and the Final rule implementing the law (76 FR 51476, August 18, 2011). The statute gives HHS broad authority to implement the data reporting requirements and imposes a 2 percent penalty on the annual update to the standard rate used to calculate Medicare payments. The Final rule directs LTCHs to a manual explaining data submission, which includes instruction to report even when no events occur. The board found that the CMS contractor properly imposed the penalty due to failure to report.

Cost reporting period ending December 31, 2015.

Companies: Texas Specialty Hospital of Lubbock; Novitas Solutions, Inc.

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