Applicability of Quality Reporting Requirements for Facilities Affected by California Wildfires (Updated 1/11/19)

Updated: January 11, 2019

The Centers for Medicare & Medicaid Services (CMS) is granting exceptions under certain Medicare quality reporting and value-based purchasing and payment programs to facilities, including ASCs, as well as Merit-based Incentive Payment System (MIPS) eligible clinicians located in areas affected by the California wildfires due to the devastating impact of the fires. These health care providers and suppliers will be granted exceptions without submitting a request if they are located in one of the California counties listed below, all of which have been designated by the Federal Emergency Management Agency (FEMA) as a major disaster county.

The scope and duration of the exception under each Medicare quality reporting program and value-based purchasing and payment program are described below. CMS is granting exceptions to assist these health care providers while they direct their resources toward caring for their patients and repairing structural damages to facilities. Facilities that are able to, and choose to do so, may submit their data and continue participation in the program. 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 California Wildfires (DR-4407) as of the date of this communication, are as follows:

California Counties

Butte
Los Angeles
Ventura

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 and payment programs they participate 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 the California wildfires 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 all measures during the annual submission period of January 1, 2018, through December 31, 2018. These exceptions apply to measures submitted via the QualityNet Secure Portal web-based tool, including claims-based measures calculated from submitted Quality Data Codes (QDCs). This exception does not apply, however, to claims-based measures that do not utilize QDCs for calculation purposes. We note that CMS recently removed the Influenza Vaccination Coverage Among Healthcare Personnel (HCP) measure beginning with the CY 2020 payment determination (CY 2018 reporting period).

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 1, 2018, CMS released the CY 2019 Physician Fee Schedule final rule, which established an automatic extreme and uncontrollable circumstance policy for MIPS beginning with the 2018 performance period/2020 payment year, which applies to MIPS eligible clinicians affected by triggering events that affect an entire region or locale, including the California wildfires. Given the FEMA designation, we consider the California wildfires to be such a triggering event, and the automatic extreme and uncontrollable circumstance policy therefore applies to the California counties listed above as well. MIPS eligible clinicians who are subject to the Alternative Payment Model (APM) scoring standard are not covered by the automatic extreme and uncontrollable circumstance policy. However, a MIPS eligible clinician who is subject to the APM scoring standard and who has been affected by an extreme and uncontrollable circumstance may apply for an exception in the Promoting Interoperability performance category.

The data submission period for the 2018 performance period is January 2, 2019 ‒ April 2, 2019. MIPS eligible clinicians in FEMA-designated areas affected by the California wildfires will be automatically identified, and no action is required. However, if you submit data for two or three performance categories (Quality, Improvement Activities, and/or Promoting Interoperability), you will be scored on the performance categories for which you submitted data. Your payment adjustment will be determined by your final score. Under the automatic extreme and uncontrollable circumstances policy, the Cost performance category will always be weighted at 0% and will not affect your final score, even if you submit data for the other performance categories.

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.