CMS revises COVID-19 data reporting for psychiatric, rehabilitation hospitals

CMS has revised the frequency of reporting certain COVID-19 data elements for psychiatric and rehabilitation hospitals according to a newly updated Quality, Safety & Oversight (QSO) memo.

The memo QSO-21-03-Hospitals/CAHs was updated May 27 to note that the data elements for psychiatric and rehabilitation hospitals that had been required weekly is now required only once annually and should include the data for the previous week, according to CMS.

The original memo was issued in October 2020.

The steps for the enforcement of the required data collection have also been changed, as CMS stated in the following:

1. The first enforcement action will begin following one calendar week of non-compliance. Providers will have one calendar week to demonstrate compliance.
2. Providers failing to meet the reporting requirements within one calendar week following the first enforcement notification letter will receive a second enforcement notification letter. This notification will indicate that that the provider will have one calendar week to demonstrate compliance with the reporting requirements otherwise the provider will receive the third and final enforcement notification letter, as noted in step 3.
3. Providers that have failed to meet the reporting requirements within one week following the second enforcement notification letter will receive a third and final enforcement notification letter. This notification will include a notice of termination to become effective within 30 days from the date of the notification. Failure to meet the reporting requirements within this 30-day timeframe may result in termination of the Medicare provider agreement.

The memo also notes that the enforcement process “will be ongoing throughout the PHE.”

The full QSO memo can be found online here. The original memo, with a PDF of the “Hospital Mandatory COVID-19 Reporting Enforcement Workflow,” can be found here.