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SNF Quality Reporting Program: Non-Compliance Letters

CMS provided notifications to facilities that were determined to be non-compliant with Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) requirements for Quarter 4 of CY 2016, which will affect their FY 2018 annual payment update (APU). The QRP was implemented on October 1, 2016 by the IMPACT Act of 2014. Providers are required to report on three measures that affect their FY 2018 payment:

  • Application of Percent of Patients or Residents Experiencing One or More Falls with Major Injury (Long Stay)
  • Percent of Patients or Residents with Pressure Ulcers that are New or Worsened
  • Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function

Notifications of non-compliance were placed into facilities’ Quality Improvement and Evaluation Systems (QIES) – Certification and Survey Provider Enhanced Reporting (CASPER) system on July 14, 2017 and also mailed directly to providers. Providers that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59pm PST, August 13, 2017. If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notification letter and on the SNF Quality Reporting Reconsideration and Exception & Extension webpage.

NOTE: In a final payment rule issued on Monday, CMS proposed that beginning in FY 2018, SNFs that do not satisfy the reporting requirements for the FY 2018 SNF Quality Reporting Program (QRP), would have a penalty of a 2.0 percent reduction to the SNF market basket percentage change for that fiscal year, after any applicable adjustments. With application of this penalty, those SNFs that do not meet the reporting requirements will receive a net market basket update of negative 1.0 percent for FY 2018.