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Home Health Care Policies: New Info for Hospice CAHPS Exemptions

Posted by Nathan Hope on Jan 14, 2015

Home Health Care Policies - Recently, CMS has issued additional information for hospices wishing to gain an exemption to participation in the hospice CAHPS program. A form is available for agency’s wishing to apply for exemption due to size of hospice program. The application is titled Participation Exemption for Size Form and will be submitted to the CAHPS Hospice Survey Project Team for consideration.


The additional information published by information includes:

Exception & Extension Request Process (Formally Disaster Waiver Request)

In the Fiscal Year (FY) 2015 Hospice Wage Index and Payment Rate Update final rule (79, FR 50487), the Centers for Medicare & Medicaid Services (CMS) finalized accommodations in the event a hospice is unable to submit quality data due to extraordinary circumstances beyond their control or when a systemic problem with data collection systems directly affected the ability of a hospice to submit data. 

CMS does not wish to penalize hospices in these circumstances or to unduly increase their burden during these times.  Therefore, we finalized a process for hospices to request and for CMS to grant extensions/exceptions with respect to the reporting of required quality data when there are extraordinary circumstances beyond the control of the hospice provider. 


Extraordinary Circumstances:    

Natural or man-made disasters preventing timely submission of quality data. A disaster may be widespread or affect multiple structures or isolated and affect a single site only.


Submission deadline extended. CMS can extend submission deadlines for the specified deadlines for 30 to 45 days beyond the scheduled due date applicable to other facilities.


Submission deadline waived. CMS can exempt a facility from submitting quality data for the specified deadlines without impact on the Annual Payment Update.

When an extension/exception is granted, a hospice will not incur payment reduction penalties for failure to comply with the requirements of the HQRP.  Under the finalized process, a hospice may request an extension/exception of the requirement to submit quality data for a specified time period by submitting a written request to CMS. 

This process does not preclude CMS from granting extensions/exceptions to hospices not requesting an extension/exception when an extraordinary circumstance, such as an act of nature affects an entire region or locale.

When an extension/exception to hospices in a region or locale is granted, CMS will communicate the decision through routine channels to hospices and vendors, including, but not limited to, Open Door Forums, ENews and notices on the CMS Hospice Quality Reporting website (direct link): https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Hospice-Quality-Reporting

Extension and Exemption Process

The HQRP does not have a specific extension or exemption request form.  Instead, a hospice will be required to submit an email request within 30 calendar days of the date the extraordinary circumstance occurred. 

Submit an Extension or Exemption Request

Extension or exemption requests and supporting documentation must be submitted via email with the subject line that contains the text: “ACA 3004 Extension and Exemption Request” and the Hospice CCN (e.g., ACA 3004 Extension and Exemption Request, CCN = XXXXXX) to the following email address: HospiceQRPReconsiderations@cms.hhs.gov.

The request must include the following information:

  • The Hospice CMS Certification Number (CCN);
  • The Hospice business name;
  • The Hospice business address;
  • The Administrator contact or designee representative information, including name, email address, telephone number, and physical mailing address; and
  • The reason(s) for requesting an extension or exemption;
  • Time period the hospice wishes to request an extension or exemption.

The request for extension or exemption must be accompanied by supporting documentation demonstrating need.  CMS will be unable to review any request that fails to provide the necessary documentation along with the request. 

Supporting documentation must include the following:

  • Proof of an extraordinary circumstances beyond the hospices control (for example, natural or man-made disasters) (may be in the form of a news article, pictures, or other documentation attesting to the incident);
  • Includes Dates of occurrence; and
  • Other documentation that may support the rationale for seeking extension or exemption.

CMS Response

  • CMS will provide written acknowledgment upon receipt of the request to the Administrator or Administrator designee contact provided in the request.
  • CMS will determine whether the evidence submitted supports the extension or exemption request.  The determination will be made based solely on the documentation provided.  CMS will not contact the hospice to request additional information or to clarify incomplete or inconclusive information. 
  • CMS will provide written notification of the decision to the Administrator or Administrator designee indicated in the request.  The response usually occurs within 30 days of receipt of the request.

If clear evidence to support the need for an extension or exemption exists, CMS will provide the extension or exemption for a determined period of time. If no clear evidence to support the need is given, the request will be denied.

For more information, visit: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Hospice-Quality-Reporting/Extensions-and-Exemption-Requests.html


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