We successfully defended a national hospice provider against Centers for Medicare & Medicaid Services’ (CMS) determination that the provider failed to meet Hospice Quality Reporting Program (HQRP) requirements for Calendar Year 2021. This alleged non-compliance would have resulted in a 2% reduction in the provider’s annual payment update for Fiscal Year (FY) 2023. Through the HQRP reconsideration process, Bass Berry & Sims successfully demonstrated that CMS’ determination of non-compliance was erroneous because CMS’ inadvertent termination of the provider caused a systemic problem with the provider’s submission of requisite HQRP, Hospice Item Set data. At reconsideration, CMS reversed its initial determination of non-compliance and granted the provider the full FY 2023 annual payment update.