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Guidance for Hospital Reporting of COVID-19 Data

CMS published new guidance and FAQs on how it will implement an interim final rule requiring hospitals to report COVID-19 data as part of Medicare conditions of participation.

The interim final rule established that hospitals and critical access hospitals must report certain information including, but not limited to: number of staffed beds; number of occupied intensive care unit beds; information about supplies, such as ventilators and personal protective equipment; and current number of laboratory-confirmed COVID-19 patients.

In a memorandum to state surveyors, CMS sets forth compliance standards for hospitals to:

  • report data on a daily basis (except for supply data, which is required only once per week, on Wednesday). Exceptions include psychiatric and rehabilitation hospitals, which only are required to report all data once per week, on Wednesday;
  • update information by the end of the next business day if unable to report on weekends;
  • voluntarily report on six new influenza fields starting Oct. 19 (with the intention that these fields will become mandatory in coming weeks); and
  • report staffing- and remdesivir-related data through Nov. 4, with optional reporting thereafter.

Enforcement Process

CMS on Oct. 7 began sending letters regarding status of compliance.

Hospitals have three weeks after the initial notification to comply; those still failing to submit data will receive a second letter and three additional weeks to comply, after which they will receive a series of enforcement notification letters each week. Hospitals that remain noncompliant will receive a third and final enforcement letter allotting 30 days for compliance before they are terminated them from the Medicare program.

CMS acknowledges there might be issues with the transmission of data or meeting data reporting requirements. As such, providers may submit evidence of such issues to CMS within 72 hours of receiving notification of noncompliance. Hospitals also have an opportunity to work with the Department of Health and Human Services to develop a plan to meeting these requirements. For questions, contact

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Maryellen Guinan is a principal policy analyst at America's Essential Hospitals.

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