The Nursing Home Quality Reporting Program (QRP) is often talked about in compliance meetings and survey prep sessions, yet it remains one of the most misunderstood CMS programs. Many facilities don’t realize that QRP is not about scoring high-it’s about reporting correctly and completely.
And the stakes are real: failure to meet QRP requirements results in an automatic 2% reduction to your Medicare Part A Annual Payment Update (APU).
Let’s break down what QRP is, why CMS cares so much about it, and most importantly, what nursing homes can do today to protect their Medicare revenue.
The Nursing Home Quality Reporting Program was established by CMS under the Improving Medicare Post-Acute Care Transformation (IMPACT) Act. Its purpose is to ensure standardized, resident-level quality data is collected across post-acute care settings. In plain language:
Physical changes:
• QRP requires nursing homes to submit specific MDS data
• The focus is on accuracy and completeness, not performance
• Compliance determines whether a facility receives its full Medicare APU
If a facility does not meet CMS’s QRP reporting requirements, CMS applies a 2% reduction to the Medicare Part A rate update for the applicable fiscal year.
This penalty is applied across all Medicare Part A claims—not just a single resident or short time period.
A critical clarification:
• QRP = Did you report the required data correctly and on time?
• VBP = How did you perform compared to other facilities?
A facility can have:
• Excellent clinical outcomes
• Strong survey results
• Solid Five-Star ratings
…and still receive the 2% QRP penalty if reporting requirements are missed.
CMS uses the Minimum Data Set (MDS) as the primary mechanism for QRP data collection.
Key quality measures include:
• Change in functional status
• Skin integrity and pressure ulcers
• Falls with major injury
• Use of antipsychotic medications
• Discharge function and mobility
The most important operational takeaway: If it isn’t coded correctly on the MDS, CMS considers it not reported.
CMS evaluates QRP compliance based on:
• Submission threshold (generally 90% or higher)
• Timely transmission of required MDS assessments
• Valid data (not dash-filled or incomplete where prohibited)
CMS publishes QRP compliance status annually through:
• CASPER reports
• Provider Preview Reports
• Certification and Survey Provider Enhanced Reports (CASPER)
Facilities that fail to meet requirements are notified-but by then, the penalty is already locked in.
For a nursing home with $2 million in annual Medicare Part A revenue a 2% reduction equals several thousand dollars lost in a year – and because Medicare rates compound annually, the long-term impact can be significantly higher.
The good news? QRP penalties are 100% preventable.
1. Treat QRP as a Revenue Protection Program
QRP is not just a compliance exercise—it is a Medicare reimbursement safeguard. Assign clear accountability to someone who understands both MDS coding and Medicare financial risk.
2. Monitor CASPER QRP Reports Monthly
Do not wait for the annual Provider Preview Report. Facilities should:
• Run QRP-related CASPER reports monthly
• Confirm submission thresholds are being met
• Identify missing or rejected assessments early
3. Strengthen MDS Coding Accuracy
Common QRP failures stem from:
• Incomplete Section GG coding
• Dash-filled required items
• Missed assessment windows
Regular MDS audits—especially focused on QRP elements—are essential.
4. Educate the Interdisciplinary Team
QRP data does not come from one person. Nursing, therapy, and clinical leaders must understand:
• Why their documentation matters
• How it flows into the MDS
• How errors can translate into lost Medicare revenue
5. Verify Data Before It’s Too Late
Once CMS’s submission deadline passes, corrections are limited or impossible.
Best practice:
• Internal deadlines that precede CMS deadlines
• Final QRP checks before quarter close
CMS designed the Nursing Home QRP to promote transparency and standardized quality data—not to be punitive. Yet every year, nursing homes lose millions in Medicare revenue due to preventable reporting gaps.
The takeaway is simple:
• QRP is about reporting, not performance
• The 2% Medicare reduction is avoidable
• Proactive monitoring and MDS accuracy protect revenue
For nursing homes willing to operationalize QRP instead of reacting to it, the program becomes far less mysterious—and far less costly.
CMS is the authoritative source for QRP requirements, technical guidance, and compliance determination. Facilities should routinely review CMS QRP manuals, MLN articles, and CASPER resources to stay current.
Michelle Stober, RN, BSN
CEO
