The Centers for Medicare & Medicaid Services (CMS) on Tuesday issued an unexpected interim final rule that, among other provisions, makes collecting and reporting COVID-19 data a condition of participation (CoP) for hospitals that participate in Medicare. By making this data reporting a CoP, the penalty for a hospital’s noncompliance potentially may mean termination from the Medicare program if appropriate corrective action is not taken.

The rule also implements new laboratory reporting requirements in accordance with the Coronavirus Aid, Relief and Economic Security (CARES) Act. Failure to comply with these requirements could result in civil monetary penalties of $1,000 a day for the first day and $500 a day for each subsequent day.

AzHHA knows our members are putting forward a good faith effort to report data needed to battle COVID-19 under very trying circumstances, and despite ever-changing requests from the government. We will continue to brief members on our work with state and federal leaders on this issue.