CMS Clarifies Home Health Quality Reporting Program Requirements

The Centers for Medicare and Medicaid Services (CMS) has just issued a tip sheet summarizing the status of the Home Health Quality Reporting Program (HH QRP) during the COVID-19 Public Health Emergency (PHE). The tip sheet also provides information on HH quality data submission requirements starting July 1, 2020, now that the temporary HH QRP exemptions from the COVID-19 PHE have ended.

Quality data for the HH QRP are submitted using the Outcome and Assessment Information Set (OASIS) and the Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Home Health Survey. On March 27, 2020, CMS announced that it was temporarily lifting the requirements for home health agencies (HHAs) to report QRP data to assist them during the COVID-19 PHE. Under this relief, HHAs were excepted from reporting data on measures and standardized patient assessment data required under the QRP for the following periods:

• Oct. 1, 2019 – Dec. 31, 2019 (Q4 2019);
• Jan. 1, 2020 – March 31, 2020 (Q1 2020); and
• April 1, 2020 – June 30, 2020 (Q2 2020).

The temporary exception for HH quality reporting requirements ended on June 30, 2020. Starting on July 1, 2020, HHAs are expected to resume timely quality data collection and submission of measure and patient assessment data for the OASIS/CAHPS®.

For this purpose, the CAHPS® Home Health Survey will be required for Q3 2020 and onward. The Home Health Care CAHPS (HHCAHPS) requirements for the Annual Payment Update (APU) run from April through the following March. For the calendar year 2022 APU, HHAs must submit monthly lists to their HHCAHPS-approved survey vendors for April 2020 through March 2021. Due to the COVID-19 exceptions, agencies are not required to submit data for Q2 2020 (April – June 2020). The HHCAHPS-approved survey vendors must submit survey data on the third Thursday in the months of January, April, July (i.e., July 16, 2020), and December.

Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866