The hospice quality reporting program (HQRP) quarterly update has been recently posted, including a reminder that the HQRP annual payment update penalty for providers not compliant with calendar year 2022 submission requirements jumps from two percent to four percent.
In addition, there are updates related to public reporting, Q&A, and new HQRP resources among other updates. In addition to the quarterly update, there are a few items of note related to the HQRP.
- Hospices are reminded that the Hospice Visits in Last Days of Life (HVLDL) and the CAHPS Hospice Survey Star Rating will be posted to Care Compare this month. As reported previously, these measures were to be publicly reported in May of this year but were delayed due to an error in the provider preview reports.
- The HVLDL was formally endorsed by the National Quality Forum (NQF) at the end of July. NAHC and others submitted comments to the NQF about concerns with the HVLDL, primarily that it does not represent the care being provided to beneficiaries since it includes only RN and SW visits and does not include telehealth visits. We included concerns in our comments to the NQF about the data used by the Centers for Medicare and Medicaid Services (CMS) in deciding which types of visits should be included in the measure. While NQF ultimately endorsed the measure it recommended that CMS continue to develop the measure. Comments submitted that highlighted the concerns about the measure were an important component to this recommendation. NAHC also shared concerns about the HVLDL in the response to the FY2023 hospice proposed wage index and payment update and quality reporting program update rule. CMS acknowledged the comments in the final rule and indicated it is considering these comments.
- Notification to non-compliant hospice providers based on their CY 2021 quality data impacting FY 2023 payments was disseminated in July. Providers can find the notifications in their CASPER folders and should receive a notification from their Medicare Administrative Contractor (MAC). Providers have thirty (30) days from the date on the notification of non-compliance to submit a request for reconsideration. More information on the timeline for this process can be found in the quarterly update and on the CMS HQRP Reconsideration Requests webpage.
- Hospices are reminded that the Hospice quality reporting data submitted in CY 2022 data, starting on January 1, 2022 impacts FY 2024 payments. Beginning with FY 2024, the APU penalty doubles, going from 2% to 4%, for hospices not meeting the HQRP requirements. To ensure hospices achieve the full APU, be certain to meet the quality reporting requirements for data submission in CY 2022:
| Annual Payment Update | HIS | CAHPS |
| FY2024 | Submit at least 90 percent of all HIS records within 30 days of the event date (patient’s admission or discharge) for patient admissions/discharges occurring 1/1/22 – 12/31/22. | Ongoing monthly participation in the Hospice CAHPS survey 1/1/2022 – 12/31/2022 |
Most hospices that receive the APU penalty do so because of noncompliance with the Hospice Item Set (HIS) submission requirements. This frequently occurs during changes in EHR systems and changes in staffing so hospices should be sure to confirm submission of the HIS timely by downloading the Final Validation Reports. This report identifies HIS submissions received by CMS, and this receipt must occur in order for the hospice to receive “credit” for having submitted the HIS.
5. CMS has added some new resources for the HQRP which are below. CMS also indicated that it plans to host a Forum in September, but no dates have been provided yet. Stay tuned to NAHC Report for more information as it becomes available.
A) Hospice Care Index (HCI) Explanatory Video: CMS has developed a new video resource explaining the purpose and design of the claims-based HCI quality measure. This video provides an overview of the new HCI claims-based measure, which combines several quality indicators into a single index score.
B) HQRP Explanatory Video: The video introduces the purpose of the HQRP, how data is collected for use in HQRP, and the quality measures included in HQRP.
The reconsideration period for the FY2023 annual payment update (APU) hospice quality reporting program (HQRP) requirements is coming up. Hospice providers will receive notification from their Medicare Administrative Contractor (MAC) if they are subject to the APU penalty, and they will also receive notification in their CASPER folder.
