How the SPARCS Compliance Calendar Works: From Reporting Period to Statement of Deficiency

By Two Pillars & Co Advisory Group · Sources checked October 2026

Why does SPARCS use a quarterly compliance calendar?

SPARCS submission is monthly, but the Department reviews compliance by calendar quarter. Every month the program evaluates two measures, submission and volume, in preparation for the quarterly reporting period.^[1] Grouping months into quarters gives facilities a predictable rhythm: a window to submit, a window to reconcile, and, if needed, a defined series of notices.

The protocol sets out this rhythm so that facilities can plan around it. It is deliberately gradual. A facility does not move from a missed target to a formal deficiency in one step; it passes through several stages, each with an opportunity to fix the problem and to talk to the program. That structure is worth understanding in advance, because the stages that look quiet from the outside, such as reconciliation, are where most compliance problems are actually solved.

What happens in the reporting period?

The reporting period is the quarter in which service dates occur. During it, the protocol says, facilities should actively submit their current data at least monthly, and should correct errors flagged by the edits in the submission portal so that rejected records can be resolved.^[1] The program also sends monthly reminders to the SPARCS Coordinators of facilities that fail to submit inpatient or outpatient data, or that are not meeting anticipated volume levels.^[1]

This is the cheapest time to fix problems. A record rejected for a missing code can be corrected by the registration team while the encounter is recent. Months later, the same fix may require chasing records through a vendor or an archived system. Many compliance teams therefore treat the reporting period as the time to keep rejections near zero, rather than waiting for the reconciliation period to deal with them.

What is the reconciliation period?

The reconciliation period is the 90 days that follow the end of the reporting quarter. According to the protocol, facilities use it to reconcile any differences between the data in their own systems and the data that SPARCS accepted, to correct data that was rejected, and to resubmit until it is accepted. If a facility uses a vendor, it should work with the vendor to build a reconciliation process that avoids periods of non-compliance.^[1]

The reporting and reconciliation periods together make up the 180-day window that the regulation allows for 100 percent of data to be submitted.^[1] The phrase “reconciliation” is easy to treat as an administrative step. In practice it is a comparison: how many discharges and visits did our system record, how many did SPARCS accept, and why do the numbers differ? A weekly audit report from the Department makes that comparison possible.^[3]

What are the warning notices, Statement of Deficiency and Plan of Correction?

If, after the reconciliation period, a facility has not met the submission or volume metrics for any month in the quarter, it is considered non-compliant and enters the out of compliance period. The program then sends warning notices to the SPARCS Coordinator. The facility CEO or administrator is included on the third as a courtesy, because a Statement of Deficiency may follow.^[1]

The protocol defines a Statement of Deficiency, or SOD, as a formal notice of non-compliance issued when a facility has failed to engage with the SPARCS program in good faith to resolve submission issues. The facility must respond with a Plan of Correction within 15 days of receiving the SOD, describing what it will do to come into compliance and giving a detailed timeline.^[1]

What are the consequences of continued non-compliance?

The protocol states that if a facility does not respond to the SOD, or does not come into compliance within the timeline in its Plan of Correction, it may be in violation of the SPARCS regulation. The program then refers the matter to the Department’s Division of Legal Affairs, which reviews the circumstances and prior communications. If a violation is established, the facility is notified that an administrative proceeding will begin, and an Administrative Law Judge can assess penalties.^[1]

The July 2026 submitter forum added current context. The program reported that all calendar year 2025 records were due by June 30, 2026, that compliance warning notices had been sent from April to June, and that the number of facilities on the annual reconciliation list had fallen from approximately 88 to 27. It said Statements of Deficiency would be issued to facilities that remained non-compliant and that failure to meet approved timelines could result in monetary penalties.^[2]

None of this means a facility with a problem is without options. The protocol encourages facilities that receive warning notices to contact the program as soon as possible to discuss barriers, including extension or exception requests.^[1] Responding early, with specifics, is consistently the safest course.

Frequently asked questions

What to do next

1. Identify which quarter your facility is currently reconciling and who owns it.
2. Compare accepted records with your own system’s counts each month.
3. If a notice arrives, answer it promptly and in writing.
4. Where a real obstacle exists, request an extension or exception before the window closes.