On July 22, 2025, the Centers for Medicare and Medicaid Services (CMS) sent their annual notification regarding non-compliance letters to inpatient rehabilitation facilities (IRF) that includes information about a potential 2% payment penalty for failure to meet quality reporting requirements. The notification stated:
The Centers for Medicare & Medicaid Services (CMS) is providing notifications to facilities that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2024, which will affect their FY 2026 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MAC) and were placed into facilities’ CASPER folders in QIES for Hospices, and into facilities’ My Reports folders in the Internet Quality Improvement and Evaluation System (iQIES) for IRFs, LTCHs, and SNFs, on July 21, 2025. Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, August 26, 2025.
If you receive a notice of non-compliance and would like to request a reconsideration, see the instructions in your notice of non-compliance and on the appropriate QRP web page:
Members are encouraged to review the appropriate folder in the CMS Internet Quality Improvement and Evaluation System (iQIES) to verify whether you have been identified for a FY 2026 penalty.
RCPA is a member of the American Medical Rehabilitation Providers Association (AMRPA), and they have been directly involved in supporting IRFs with the reconsideration process. They recently provided the following information:
Should you receive a non-compliance letter, AMRPA stands ready to support your IRF with the reconsideration process. Additional information is available on the AMRPA IRF QRP Reporting Program website, including content produced two years ago that is still applicable to this process. AMRPA and the FAIR Fund jointly provided a webinar and a Reconsideration Request Template letter for use by any AMRPA member facing a noncompliance determination.
Should you have any questions or need any additional assistance, please contact Troy Hillman. In reaching out, we ask that you provide the following information:
- A copy of the CMS non-compliance letter;
- A copy of the IRF QRP Provider Threshold Report from iQIES with the report date range of calendar year 2024; and
- If CDC measures are identified as the issue(s), a copy of any CDC NHSN Reports, which show the monthly data submissions in Calendar Year 2024 for the Catheter Associated Urinary Tract Infection (CAUTI), Clostridium difficile Infection (CDI), COVID-19 Vaccination Coverage among Healthcare Personnel (HCP), and/or Influenza Vaccination among Healthcare Personnel measures.