APU Reconsideration Process – Fiscal Year 2019

Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program

The Centers for Medicare & Medicaid Services (CMS) provides Inpatient Psychiatric Facilities (IPFs) the opportunity to request a reconsideration of an Annual Payment Update (APU) decision. Facilities requesting IPFQR Program reconsideration from CMS must submit their Reconsideration Request Form to the IPFQR Support Contractor (SC) within 30 days following the date of receipt of the IPFQR Annual Payment Update (APU) Notification Letter. CMS will officially respond to the reconsideration request submitted by each facility.

Reconsideration requests must be sent to the IPFQR SC via one of the following methods:

  1. QualityNet Secure Portal to the Secure File Transfer "APU" group.
  2. Secure fax to IPFQR Support at (877) 789-4443.
  3. Email to QRSupport@HCQIS.org.

Your request must identify the facility’s specific reason(s) for believing the IPFQR Program requirements were met and why the facility should receive the full Fiscal Year (FY) 2019 IPF Prospective Payment Systems (PPS) APU.

The request must also address the failed IPFQR Program requirement(s) identified in the facility’s IPFQR APU Notification Letter. These requirements include:

  1. At least one active QualityNet Security Administrator, who followed and completed the Security Administrator Registration Process on QualityNet before the IPF begins reporting, regardless of the method used for submitting data.
  2. An IPFQR Program Notice of Participation (NOP) status of “Participating”.
  3. Collection and submission of data by the August 15, 2018, submission deadline, unless otherwise indicated:
    • The Influenza Vaccination Coverage among Healthcare Personnel (HCP) measure data due to the National Healthcare Safety Network (NHSN) – Deadline May 15, 2018
    • Annual, aggregate data for Hours of Physical Restraint Use (HBIPS-2), Hours of Seclusion Use (HBIPS-3), Patients Discharged on Multiple Antipsychotic Medications with Appropriate Justification (HBIPS-5); Substance Use (SUB-1, SUB-2/-2a, SUB-3/-3a); Tobacco Use (TOB-1, TOB-2/-2a, TOB-3/-3a); Transition Record with Specified Elements Received by Discharged Patients, Timely Transmission of Transition Record, Screening for Metabolic Disorders, and the Influenza Immunization (IMM-2) measures.
    • Attestation as to the Use of Electronic Health Record (EHR) and Assessment of Patient Experience of Care at the IPF, as of December 31, 2017
    • Non-measure data collected during calendar year 2017
  4. Complete a Data Accuracy and Completeness Acknowledgement (DACA), by the submission deadline.

CMS will acknowledge receipt of your reconsideration request. An official response to your reconsideration request will be sent to the Chief Executive Officer (CEO) identified on the reconsideration request form within 90 days of the request.

If you have questions about the IPFQR APU Reconsideration process, please contact the IPFQR support contractor at (844) 472-4477 or (866) 800-8765.


Filing an Appeal

When a facility is dissatisfied with the result of a CMS reconsideration, the facility may file a claim under 42 CFR Part 405, Subpart R (a Provider Reimbursement Review Board [PRRB] appeal). Details are available on the PRRB Review Instructions page. An appeal can be filed with the PRRB only after the facility has submitted a request for reconsideration and received an adverse decision on the request.

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