Extraordinary Circumstances Extension / Exception (ECE) due to Hurricane Michael

Extraordinary Circumstances Extension / Exception (ECE) due to Hurricane Michael

The purpose of this communication is to notify Post-Acute Care providers of the Centers for Medicare & Medicaid Services (CMS) intent to grant quality reporting data submission and validation exceptions to Medicare providers in several care settings adversely affected by the devastating impact of Hurricane Michael, including Long-Term Care Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Hospices, Home Health Agencies, and Skilled Nursing Facilities (SNFs). CMS is issuing exceptions for several quality reporting data submission requirements because of possible damage to facilities and/or systems resulting in their inability to gather or submit data, as well as the need to prioritize immediate resources for direct patient care.

Specifically, for the specified reporting quarter(s), as indicated in this communication, affected providers will not be required to submit quality measure data to meet submission requirements.

CMS is exercising its authority to grant exceptions for data submission requirements for the above quality reporting programs for providers located within the Federal Emergency Management Agency (FEMA)-designated “major disaster” counties of Florida, and Georgia listed below:

Florida	Georgia
·         Bay ·         Calhoun ·         Franklin ·         Gadsden ·         Gulf ·         Hamilton ·         Holmes ·         Jefferson ·         Jackson ·         Leon ·         Liberty ·         Madison ·         Suwannee ·         Taylor ·         Wakulla ·         Washington	·         Baker ·         Bleckley ·         Calhoun ·         Colquitt ·         Crisp ·         Decatur ·         Dodge ·         Dooly ·         Dougherty ·         Early ·         Emmanuel ·         Grady ·         Houston ·         Jefferson	·         Jefferson ·         Lee ·         Macon ·         Miller ·         Mitchell ·         Pulaski ·         Seminole ·         Sumter ·         Terrell ·         Thomas ·         Treutlen ·         Turner ·         Wilcox ·         Worth

CMS recommends visiting the FEMA website at https://www.fema.gov for the most up to date list of counties affected by Hurricane Michael. Please note that Medicare providers located outside of the counties covered under this memo, and in need of an extension or exception from program requirements are required to follow the submission process described at the bottom of this memo.

Long Term Care Hospital Quality Reporting Program (QRP)

For the following LTCH QRP requirements and discharged quarters listed below, CMS grants a blanket exception for all LTCHs in the above-designated counties.

LTCHs participating in the CMS LTCH QRP are granted an exception from the data reporting requirements of the LTCH QRP, specifically the data submitted via the LTCH CARE Data Set (assessment-based), and data submitted via the Center for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN). Claims-based measures do not require any submission of data to CMS beyond that of data submitted via LTCH PPS claims.

LTCHs located in covered counties are granted an exception from reporting quality data to CMS, as described above, for the following reporting quarters:

• April 1, 2108 – June 30, 2018 (2^nd Quarter 2018)
• July 1, 2018 – September 30, 2018 (3^rd Quarter 2018)
• October 1, 2018 – December 31, 2018 (4^th Quarter 2018) For the following IRF QRP requirements and discharged quarters listed below, CMS grants a blanket exception for all IRFs in the above-designated counties.

Inpatient Rehabilitation Facility (IRF) Quality Reporting Program (QRP)

For the following IRF QRP requirements and discharged quarters listed below, CMS grants a blanket exception for all IRFs in the above-designated counties.

IRFs participating in the CMS IRF QRP are granted an exception from the data reporting requirements of the IRF QRP, specifically the data submitted via the assessment-based IRF-PAI (Patient Assessment Instrument) and data submitted via the Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network (NHSN). Claims-based measures do not require any submission of data to CMS beyond that of data submitted via IRF PPS claims. Please note that this exception applies to quality data only, and has no effect on the submission of the IRF-PAI for payment purposes.

IRFs located in covered counties are granted an exception from reporting quality data to CMS, as described above, for the following reporting quarters:

• April 1, 2108 – June 30, 2018 (2^nd Quarter 2018)
• July 1, 2018 – September 30, 2018 (3^rd Quarter 2018)
• October 1, 2018 – December 31, 2018 (4^th Quarter 2018)

Skilled Nursing Facility (SNF) Quality Reporting Program (QRP)

For the following SNF QRP requirements and discharged quarters listed below, CMS grants a blanket exception for all SNFs in the above-designated counties.

SNFs participating in the CMS SNF QRP are granted an exception from the data reporting requirements of the SNF QRP, specifically the data submitted via the assessment-based Minimum Data Set (MDS). Claims-based measures do not require any submission of data to CMS beyond that of data submitted via Medicare FFS claims. Please note that this exception applies to quality data only, and has no effect on the submission of the MDS for payment or other required purposes.

SNFs located in covered counties are granted an exception from reporting quality data to CMS, as described above, for the following reporting quarters:

• April 1, 2108 – June 30, 2018 (2^nd Quarter 2018)
• July 1, 2018 – September 30, 2018 (3^rd Quarter 2018)
• October 1, 2018 – December 31, 2018 (4^th Quarter 2018)

Hospice Quality Reporting Program (QRP)

For the following Hospice QRP requirements and discharged quarters listed below, CMS grants a blanket exception for all Hospices in the above-designated counties.

Hospices participating in the CMS Hospice QRP are granted an exception from the data reporting requirements of the Hospice QRP, specifically the data submitted via the Hospice Item Set (HIS) and the Hospice Consumer Assessment of Healthcare Providers and Systems (Hospice CAHPS®) survey. The CAHPS Hospice Survey exception will apply to “Q3 2018 and Q4 2018 decedents,” or hospice patients who died between July-December 2018

Hospices located in covered counties are granted an exception from reporting quality data to CMS, as described above, for the following reporting quarters:

• July 1, 2018 – September 30, 2018 (3^rd Quarter 2018)
• October 1, 2018 – December 31, 2018 (4^th Quarter 2018)

Home Health Agencies Quality Reporting Program

For the following HH QRP requirements and discharged quarters listed below, CMS grants a blanket exception for all HHAs in the above-designated counties.

HHAs participating in the CMS HH QRP are granted an exception from the data reporting requirements of the HH QRP, specifically the data submitted via the OASIS assessment instrument and Home Health Consumer Assessment of Providers and Systems Survey (HH CAHPS®). Pleasenote that this exception applies to quality data only, and has no effect on the submission of the Home Health OASIS for payment purposes

HHAs located in covered counties are granted an exception from reporting quality data to CMS, as described above, for the following reporting quarters:

• July 1, 2018 – September 30, 2018 (3^rd Quarter 2018)
• October 1, 2018 – December 31, 2018 (4^th Quarter 2018)

We would like to note that this exception from quality reporting requirements for the above-listed CMS QRPs may impact the minimum case threshold counts for calculation of quality metrics. While you can continue to submit data to CMS, any data submissions for the above-listed exempt CY 2018 quarters will not be considered when determining compliance related to the FY 2020 reporting requirements for your hospital or facility. That is, you will not be held accountable for quality data collected and submitted during the 2018 quarters identified above. Please also note that this may affect the minimum amount of data needed to calculate specific quality measures for public reporting purposes, in which case CMS would suppress the applicable data on the respective Compare sites, when quality measure data are calculated and posted.

Exception and Extension Request Process

Hospitals and Facilities in other counties and states may submit ECE Requests for data submission based on individual circumstances by one of the following processes:

• LTCH QRP: For LTCHs outside the FEMA-designated counties listed above in this notice, that were affected by Hurricane Michael, please follow the directions related to requesting an exception, as listed on the LTCH Quality Reporting Reconsideration and Exception & Extension website at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/LTCH-Quality-Reporting/LTCH-Quality-Reporting-Reconsideration-and-Exception-and-Extension.html or email questions to LTCHQRPReconsiderations@cms.hhs.gov.
• IRF QRP: For IRFs outside the FEMA-designated counties listed above in this notice, that were affected by Hurricane Michael, please follow the directions related to requesting an exception as listed on the IRF Quality Reporting Reconsideration and Exception & Extension website at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/IRF-Quality-Reporting/IRF-Quality-Reporting-Reconsideration-and-Exception-and-Extension.html or email questions to IRFQRPReconsiderations@cms.hhs.gov.
• SNF QRP: For SNFs outside the FEMA-designated counties listed above in this notice, that were affected by Hurricane Michael, please follow the directions related to requesting an exception as listed on the SNF Quality Reporting Reconsideration and Exception & Extension website at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Skilled-Nursing-Facility-Quality-Reporting-Program/SNF-QR-Reconsideration-and-Exception-and-Extension.htmlor email questions to SNFQRPReconsiderations@cms.hhs.gov.
• Hospice QRP: For Hospice providers outside the FEMA-designated counties listed above in this notice, that were affected by Hurricane Michael, please follow the directions related to requesting an exception, as listed on the Hospice Quality Reporting Exception & Extension website at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Hospice-Quality-Reporting/Extensions-and-Exception-Requests.html or email questions to HospiceQRPReconsiderations@cms.hhs.gov.

Home Health QRP: For HHAs outside the FEMA-designated counties listed above in this notice, that were affected by Hurricane Michael, please follow the directions related to requesting an exception, as listed on the HHA Quality Reporting Reconsideration and Exception and Extension web site at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/HomeHealthQualityInits/Home-Health-Quality-Reporting-Reconsideration-and- Exception-and-Extension.html