Monday, June 15, 2020

NHSN Reporting Citations and CMPs Rescinded

Some members have begun to receive notices in CASPER rescinding the F884 citation and Civil Monetary Penalty (CMP) they were given for allegedly not reporting complete information to NHSN about COVID-19 in the standardized format and frequency specified by CMS and CDC. The letter indicates that due to its internal reviews of the NSHN data submissions, CMS is deleting the F884 deficiency and rescinding the CMP imposed for the June 1-June 7, 2020 reporting week.

These rescind letters may be sent through mail and/or through CASPER as with the F884 citations and enforcement letters and may be accompanied by an email notification to facility staff that have an MDS account in CASPER. If you believe you successfully submitted NHSN data and received a citation and CMP in error, please check your CASPER folder for one of these rescind letters.

AHCA will share any further information we receive.

IIDR Sample Request on NHSN Reporting Citation

For facilities that have not received a rescind letter from CMS, but still believe the F884 citation was issued in error or inappropriately, at this time you must still submit an independent information dispute resolution (IIDR) request, as indicated in the enforcement letter. You must submit that request within 10 calendar days of receipt of the enforcement letter, which is being provided through CASPER. Be sure to include supporting documentation of your data submissions and/or documentation of your efforts to resolve any technical issues with NHSN registration or data submissions in advance of the reporting deadlines.

To assist in this process, we are sharing this sample IIDR request. This is only a sample and you must tailor it to your situation. Please review the instructions in the document before completing it and consult with your counsel in this process as appropriate.

AHCA will continue to advocate that CMS improve this process and make it fairer and more transparent.

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