Applicability of Quality Reporting Requirements for Facilities Affected by Hurricane Florence (Updated 12/5/18)

Updated: December 5, 2018

The Centers for Medicare & Medicaid Services (CMS) is granting exceptions under certain Medicare quality reporting programs, including ASCs, located in areas affected by Hurricane Florence due to the devastating impact of the storm. These health care providers and suppliers will be granted exceptions if they are located in one of the North Carolina, South Carolina or Virginia counties listed below, all of which have been designated by the Federal Emergency Management Agency (FEMA) as a major disaster county.

CMS is granting exceptions to assist these providers while they direct their resources toward caring for their patients and repairing structural damages to facilities. CMS is closely monitoring the situation for future potential widespread catastrophic events, and will update exception lists soon after any events occur in the future.

The affected counties designated by FEMA under the North Carolina Hurricane Florence (DR-4393), South Carolina Hurricane Florence (DR-4394) and Virginia Hurricane Florence (DR-4401) Major Disaster Declarations, as of the date of this communication, are as follows:

The health care providers located outside of the counties listed above are not covered by this communication, but may request an exception to the reporting requirements under one or more Medicare quality reporting or value-based purchasing programs it participates in using the applicable extraordinary circumstances exception procedure for the respective program(s). CMS will assess and decide upon each extraordinary circumstances exception request on a case-by-case basis.

If FEMA expands the current disaster declaration for Hurricane Florence to include additional counties, CMS will update this communication to reflect the expanded list of applicable counties for which health care providers would be eligible to receive an exception without submitting a request. In addition, CMS will continue to monitor the situation and adjust exempted reporting periods and submission deadlines accordingly.

Ambulatory Surgical Centers (ASCs)

CMS is granting an exception to ASCs located in the counties described above for the following reporting requirements under the Ambulatory Surgical Center Quality Reporting (ASCQR) Program:

• Data collection and submission requirements that apply for the remainder of Calendar Year (CY) 2018 and the 2018/2019 Influenza Season that relate to CY 2020 payment determinations are exempt. These exceptions apply to all data submitted via the QualityNet Secure Portal and the NHSN web-based measure collection tools that are due May 15, 2019, including claims-based measures calculated from submitted Quality Data Codes (QDCs). This exception does not apply to claims-based measures that do not utilize QDCs for calculation purposes.

Hospital IQR, OQR, and ASCQR ECE Request Process

Hospitals and ASCs in counties and states outside of the designated areas may submit ECE requests based on individual circumstances by one of the following methods:

• Secure File Transfer via QualityNet Secure Portal, “WAIVER EXCEPTION WITHHOLDING” group
• Email to QRSupport@hcqis.org
• Secure fax to 877.789.4443
• Mail to HSAG, Attention: Quality Reporting Support Contractor, 3000 Bayport Drive, Suite 300, Tampa, FL 33607

Please refer to the ECE Request process and form specific to the program of interest located on QualityNet for additional information.

• Hospital IQR Program: Select “Hospital Inpatient Quality Reporting Program” from the [Hospitals – Inpatient] tab dropdown list, followed by selecting the “Extraordinary Circumstances Form” link in the left side navigation bar.
• The National Support Team for the Hospital IQR Program is available to answer questions or supply any additional information you may need. Please contact the team at inpatientsupport@viqrc1.hcqis.org or call toll-free at 844.472.4477.
• ASCQR Program: Select “Ambulatory Surgical Center (ASC) Program” from the [Ambulatory Surgical Centers] tab dropdown list, followed by selecting the “Extraordinary Circumstances Form” link in the left side navigation bar. See the next section under the Hospital OQR Program for contact information for ASCQR Program-related issues.
• Hospital OQR Program: Select “Hospital Outpatient Quality Reporting Program” from the [Hospitals – Outpatient] tab dropdown list, followed by selecting the “Extraordinary Circumstances Form” link in the left side navigation bar.
  • The National Support Team for both the Hospital OQR and ASCQR Programs is available to answer questions or supply any additional information you may need. Please contact the team at oqrsupport@hsag.com or qrsupport@hcqis.org or call toll-free at 866.800.8756.

For questions regarding technical issues, contact the QualityNet Help Desk at the following email address: qnetsupport@hcqis.org.

MIPS Eligible Clinicians

On November 2, 2017, CMS released the CY 2018 Quality Payment Program final rule and interim final rule with comment period, which established an automatic extreme and uncontrollable circumstance policy, which applies to MIPS eligible clinicians affected by triggering events that affect an entire region or locale, including Hurricane Florence. Given the Hurricane Florence FEMA designation, we consider Hurricane Florence to be such a triggering event, and the automatic extreme and uncontrollable circumstance policy therefore applies to the North Carolina, South Carolina and Virginia counties listed above as well. Please note that the policy does not apply to MIPS eligible clinicians in MIPS Alternative Payment Models (MIPS APMs) in 2018.

The data submission period for the 2018 performance period is January 1, 2019 ‒ March 31, 2019. MIPS eligible clinicians in FEMA designated areas affected by Hurricane Florence will be automatically identified, and no action is required. However, if you are automatically identified, but still choose to submit data on two or more MIPS performance categories (either as an individual or group), you’ll be scored on those performance categories, and your 2020 MIPS payment adjustment will be based on your 2018 MIPS final score.

MIPS Extreme and Uncontrollable Circumstances Exception Information

For more information, please reference the Extreme and Uncontrollable Circumstances Overview section on the MIPS > About Exception Applications page. You can also contact the Quality Payment Program Service Center at 866.288.8292/TTY 877.715.6222, Monday through Friday, 8:00 am ‒ 8:00 pm ET or by email at qpp@cms.hhs.gov.