overview

Starting October 1, 2020, the Centers for Medicare & Medicaid Services (CMS) regulations require providers (including short- and long-term acute care hospitals, inpatient rehabilitation facilities, skilled nursing facilities, home health agencies, physicians, and all other unnamed providers) to send medical records to Kepro electronically via a Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) approved method. Kepro will pay providers $3.00 for a complete patient record sent in an electronic format. For details, see the CMS FY2021 Inpatient Prospective Payment System (IPPS) Final Rule pp. 1693-1722.

Kepro’s medical record request will provide details on how to securely submit the patient records electronically. This new requirement will affect all review types performed by the BFCC-QIO, including quality of care complaints and appeals. Providers that are unable to submit medical records electronically will need to obtain an approved waiver from Kepro. Without a waiver, Kepro cannot reimburse faxed or paper copy medical records. Detailed information about reimbursement and waivers can be found below.

Watch a video: Medical Record Submission Process

Please note that Kepro will continue to accept medical records via fax after October 1, 2020. However, these medical records will not be reimbursed until there is a signed waiver in place.  

reimbursement

The following applies on October 1, 2020:

• Electronic submission - reimbursement rate is $3.00 per patient record
• Facsimile or mail submission* - reimbursement rate is $0.15 per page for requested patient records (plus the cost of first class postage for mailed photocopies)
• These changes are applicable to all providers and practitioners providing patient records to Kepro for the purpose of BFCC-QIO reviews under §476.78

*Facsimile and mail submission reimbursement is applicable after a waiver is approved and signed by Kepro.

waivers

Providers who are unable to submit requested patient records in electronic format must request a waiver of the requirement from Kepro.

Kepro recognizes that some providers may lack the capacity to submit records in an electronic format. However, these providers and practitioners are still required to comply with requests for medical records.

Waiver form 

quality of care complaints

Providers will upload medical records to the managed file transfer (MFT) solution offered by CMS. Kepro will email the medical record request to the last email address that is on file. The medical record request will provide directions for providers to electronically upload the medical record into the MFT portal. If dates of services are incorrect, please send a list of all dates of service for the past three years. For more information, please review our provider instruction document.

frequently asked questions

Are you looking for a specific question? Click on one of these links to be directed to the appropriate category:

Questions about 

• Submission
• Reimbursement
• Waivers

submission

1. My facility is not able to submit medical records electronically yet, and we are waiting on a signed waiver from Kepro. How do we send Kepro the requested medical records?
   

   Kepro understands that providers may not be ready for this change; for that reason, Kepro will not be turning off its fax server and will process medical records received via fax. Your facility may continue to fax medical records to Kepro; however, we will not pay for those received faxes without a signed/approved waiver.

2. Will esMD be an acceptable method of transmission going forward?
   

   esMD remains an acceptable method of file transfer, but currently, esMD is not configured to fully accept medical records for either quality of care or appeal reviews. Kepro has worked with the esMD Application Developer on the proper configuration. We will provide updates as they occur.

3. Are hospitals the only provider type required to submit electronic records to the BFCC-QIOs?
   

   The Final Rule instructs all providers and practitioners to submit records to the BFCC-QIO electronically.

4. What is the provider and beneficiary protection if the submission link goes down?
   

   This question is best answered by the Centers for Medicare & Medicaid Services (CMS). That said, Kepro will not turn off our fax server and therefore, does not intend for there to be delays. Providers can continue to submit via fax while working on their internal process changes in order to meet CMS’ requirement for electronic submission.

5. Will you accept multiple files for the submission of records for a beneficiary?
   

   Providers will have two options for the submission of electronic medical records. One submission will be for the quality of care reviews required by CMS; the other for the appeals. 
   
   For quality of care reviews, providers will receive a telephone call asking providers for an email address to which we will send a secure medical record request. On the medical record request, providers will have a site where they can access and upload the requested medical record. Once received. those medical records will be electronically connected to the quality of care review in CMS' designated case review system - known as QMARS. To the best of our knowledge, this process can allow for multiple submissions, not multiple files (one upload per submission).
   
   For appeals, CMS has allowed BFCC-QIO contractors to continue to work within their proprietary case review systems. In order to submit records or data securely, the provider will use our portal.  When a provider uses our portal for submission of records, the data submitted is secure in transit. This is accomplished by using encryption protocol. Our system/portal allows for one file attachment per submission. However, multiple submissions are accepted for a single case. We will continue to work on enhancing our portal and hope to be able to allow for multiple file attachments in a single submission in the near future.

6. Is there a file size limit on the submissions?
   

   It is our understanding that files must be less than 200 MB in size for both systems.

7. How is the beneficiary identified, and do we need to name the file following a specific convention?
   

   For quality of care submission of records, the provider will be given a QMARS-generated medical record number that will need to be used when uploading the requested medical record.
   
   For appeals, the provider will need to use the appeal number (format: yyyymmdd_123_AB) upon opening the portal. This appeal number will be validated with Kepro’s internal system to ensure there is an open/active case. Once the validation is complete, the right side of the portal will open, and the provider can upload the requested medical record. 

8. How does my organization upload to the medical record submission portal beginning October 1? Can files saved on the computer be uploaded? We would like to be preemptive instead of waiting to receive a request with the instructions.
   

   Kepro’s portal is now available to the provider community as of October 1, 2020. We would recommend providers work with their Information Technology departments regarding the best practice for uploading the requested medical records. Different providers have different requirements regarding the saving of PHI on their computer systems. It would be best to follow the provider specific requirements.

9. With most common nursing software, the records are not integrated. This means that any given SNF likely has three sources of essential documentation - nursing software, therapy software, and paper. How will this affect the process?
   

   At the current time, SNF providers are faxing this level of detail to the BFCC-QIO for a specific appeal. It may require SNF providers to scan these various components of the requested medical record and upload the file into the portal. Until such time as the SNF providers can accomplish this, fax transmission is still an option.

10. Will a specific cover sheet be required? How will we receive it, if so?
    

    For the quality of care submission of records, the provider will be given a QMARS-generated medical record number that will need to be used when uploading the requested medical record.
    
    For appeals, the provider will need to use the appeal number (format: yyyymmdd_123_AB) upon opening the portal. This appeal number will be validated with Kepro’s internal system to ensure there is an open/active case. Once the validation is complete, the right side of the portal will open, and the provider can upload the requested medical record.

11. Many patient discharge appeals occur in the evening or weekends when there is no health information management (HIM) staff with access to online uploading. Is it correct to say that we can fax them on the weekend and the only "penalty" is that we will not be paid $3 as we would if we transmitted electronically?
    

    Hospital discharge appeals, by their very nature, have a short turnaround time frame for the request and receipt of medical information. The Weichardt settlement and CMS instructions state the hospital has to provide the medical information to the BFCC-QIO by 12 pm (local time) on the day following notification of an appeal request. Due to this requirement, many, if not most, hospitals have designated weekday and weekend/off hours contact information which has been shared with the BFCC-QIOs. CMS is allowing both BFCC-QIO contractors to continue to use their proprietary appeal systems. Kepro will continue to notify the hospital-designated individuals with appeal requests by telephone and fax. Our outbound medical record request will include the web portal where the hospital can upload their medical records. Kepro will keep open its fax lines for a period of time, so that providers can continue faxing them while working on their internal systems. Should medical records be faxed, there will be no reimbursement unless the hospital has a signed waiver from Kepro. 

12. Is Kepro using Transport Layer Security (TLS) 1.2 or higher as your secure protocol to receive these records? All previous versions of TLS have been shown to be susceptible to hacking and compromise.
    

    Kepro protects data using TLS 1.2  and 1.3. 

13. My file is more than the 200 MB file size limit. How can I upload my medical record to Kepro?
    

    It is not necessary to scan on a high resolution for the medical records. The higher the resolution of the file, the larger it is, which will be more difficult to send. The default setting on scanners tends to be a high resolution. Please adjust the resolution settings, rescan the medical records, and try uploading them again. If possible, pdf files are recommended. 

14. On pp. 1705 of the FY2021 IPPS Final Rule, it was proposed and finalized that all providers and practitioners will have 14 calendar days to submit their requested patient records to the QIO in electronic format, effective 10/1/20. There is contradictory verbiage on your website, which references a 1 day submission deadline. 
    

    There are distinct time frames for the various mandatory reviews such as quality of care, appeals, and EMTALA. The CMS reference is for the quality of care (QOC) reviews. Providers do have 14 calendar days to submit those records. That is not the time frame for appeals. The due date/time noted on the appeal fax document is correct. 

15. Our hospital currently sends an electronic fax through our EMR. If we continue, does that require a waiver?
    

    The 2021 IPPS rule change (CMS-1735-F) states that providers and practitioners must securely transmit BFCC-QIO requested medical records in an electronic format. CMS does not consider fax transmission to be electronic. If a provider or practitioner lacks the ability/capacity to submit requested medical records to the BFCC-QIO, they may request a waiver from CMS' requirement.

16. The new 2021 IPPS rule change (CMS-1735-F) references providers. How does this rule affect Medicare Advantage plans?
    

    Medicare Advantage plans would be considered a provider when they are paying for care or services for a beneficiary. In the 2021 IPPS rule, a "provider" is defined as a healthcare facility, institution, or organization involved in the delivery of healthcare services for which payment may be made in whole or in part under Title XVIII of the Act. Kepro understands that providers may not be ready for this change; for that reason, Kepro will not be turning off its fax server and will process medical records received via fax. Providers may continue to fax medical records to Kepro; however, we will not continue to pay for those received faxes without a signed, approved waiver.

17. My certified EHR will not allow me to export or transmit the patient records requested by Kepro. To whom can I report this problem?
    

    This could constitute “Information Blocking” under the 21st Century Cures Act. Please refer to the Office of the National Coordinator for Health Information Technology’s (ONC) website defining information blocking practices, and exceptions to information blocking: https://www.healthit.gov/topic/information-blocking
    
    If you believe that the problems you are experiencing with your EHR is the result of information blocking practices, please use ONC’s online form to report your experiences.

reimbursement

1. Is Kepro currently paying the per page amount for faxed records? Most hospitals do not invoice for that fee, but the regulation indicates that the QIO should be paying it, even without an invoice.
   

   Prior to the publication of FY2021 IPPS Rule, the BFCC-QIO contractors had no authority to reimburse for fax transmissions. We were required to pay for hard copy medical records and first-class postage; should the provider send in the medical record via encrypted CD/DVD, we were required to pay for first class postage only.

2. How will we receive payment for the electronic uploads? Will direct deposit be an option?
   

   At the current time, Kepro will be sending providers reimbursement checks. That format may change in the future, and if it does, we will provide updated information.

3. For hospital providers, who receives the reimbursement for the electronic submission?

   Payment will be made using the hospital’s contact information that is listed on the Memorandum of Agreement.

4. Do I need to send an invoice in order to get paid for electronic submissions?

   There is not a need for the hospital to send us an invoice for reimbursement. Our systems have collected the necessary information and will make appropriate reimbursement on a monthly basis.

waivers

1. When will the waiver request document be available?
   

   The Waiver Request for Electronic Submission of Requested Medical Records is available as an on-line form.

2. If a facility is simply not ready to begin this process, is that sufficient reason to request a waiver?

   Kepro understands that providers may not be ready for this change; for that reason, Kepro will not be turning off its fax server and will process medical records received via fax. Your facility may continue to fax medical records to Kepro; however, we will not pay for those received faxes without a signed/approved waiver.

3. If providers do not request reimbursement, can they fax with the bar-coded cover sheet using the current process for discharge appeals? Does fax submission require a waiver?
   

   Kepro will not be turning off its fax server and will process medical records received via fax. Your facility may continue to fax medical records to Kepro; however, we will not pay for those received faxes without a signed/approved waiver.

4. Can my organization submit one waiver to cover all our healthcare providers and practitioners?
   

   Each provider must have an individual waiver.