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Process to dispute condition-level survey findings before enforcement
The informal, non-appealable process a hospice may use to contest condition-level survey findings before formal enforcement, requested within the 10-day plan-of-correction window; it does not pause enforcement timelines.
Informal Dispute Resolution (IDR) is a CMS process, effective January 1, 2024, that lets a hospice informally dispute condition-level survey findings before formal enforcement and appeals. It cannot be used to dispute standard-level findings, to refute enforcement actions, or to contest selection into the Special Focus Program.
CMS finalized the hospice IDR process in the CY2024 Home Health final rule (published November 13, 2023), effective January 1, 2024, with hospices following the same IDR process already used for home health agencies as reflected in State Operations Manual Chapter 10 (https://www.federalregister.gov/documents/2023/11/13/2023-24455/medicare-program-calendar-year-cy-2024-home-health-hh-prospective-payment-system-rate-update-hh; https://www.cms.gov/files/document/qso-24-11-hha-hospice.pdf). When a hospice receives its survey findings on Form CMS-2567, it is notified of its right to request IDR to dispute any condition-level findings, and it must submit that request within the 10-calendar-day window allowed for submitting the plan of correction [1].
The IDR is conducted by the State survey agency or CMS Location that performed the survey; the process must be in writing and available for review upon request, and the State agency remains responsible for IDR decisions even if it involves outside reviewers [1]. If the State or CMS removes or revises a finding as a result, Form CMS-2567 is updated and any related enforcement action is adjusted [1]. IDR does not delay enforcement timelines and applies only to condition-level findings — it is not an appeal and does not substitute for formal appeal rights [1].
IDR provides a 10-calendar-day window that coincides with the plan-of-correction deadline, and it does not pause the enforcement clock. Because condition-level findings are the only findings eligible for IDR — and because those findings drive SFP algorithm scoring, mandatory revisits, and enforcement exposure — a successfully overturned condition-level finding removes an algorithm input and a potential termination trigger. The IDR process is the only informal mechanism available to a hospice for challenging a condition-level deficiency before it becomes part of the enforcement and SFP record.
The hospice IDR process became effective January 1, 2024, as finalized in the CY2024 Home Health final rule [2].
A hospice must request IDR within the 10-calendar-day period allowed for submitting its plan of correction after receiving the Statement of Deficiencies (CMS-2567) [1].
IDR can be used only to dispute condition-level findings; it cannot be used for standard-level findings, to refute enforcement actions, or to contest selection into the Special Focus Program [1].
No — IDR does not delay enforcement timelines, so hospices must continue meeting plan-of-correction and enforcement deadlines while IDR is pending [1].
Vitalis Care is the end-of-life care app that helps hospices deliver compassionate care — while staying on top of schedules, field operations, documentation, compliance, and reimbursement.
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