The Health Group, LLC | The Health Group, LLC | Offering a vast array of financial, strategic, clinical, IT, and billing consulting services.

 

 

Our Affiliate:

The Health Group, LLC

 

 

The Health Group, LLC is available to meet the cost reporting, corporate compliance, Medicare enrollment and state licensure, strategic planning, accounting and financial reporting assistance, merger/acquisition and general healthcare financial consulting needs of healthcare providers.  These services are provided by professionals of The Health Group, LLC and our network of professional resources across the country.

 

Our professionals have extensive experience working with hospitals, nursing homes, physician practices, clinics, hospice, home health, HME and other healthcare providers.  We focus on providing services that assist our clients to accomplish their respective objectives.

 

Our clients are located across the country.  Whether your organization is proprietary, tax-exempt, or governmental; free-standing or provider-based, we have the resources to meet your healthcare financial needs.

 

Additionally, we provide extensive educational information and updates to our clients, our referral sources, and others in support of the healthcare industry including national and state healthcare associations.  We look forward to hearing from you or meeting with you to discuss how The Health Group, LLC can be a valuable resource in your healthcare endeavors.

Hospice Cost Report Revisions
Proposed Rule Regarding Overpayments
Hospice Required to File Cap Reports

The U.S. Centers for Medicare & Medicaid Services (“CMS”) has released its second draft of the revised, new, Hospice Cost & Data Report. The report requires extensive changes in reporting financial and statistical information based on the four levels of care (“LOC”). Hospices will need to modify their existing chart of accounts as well as processes for the accumulation of financial and statistical information.

The Hospice Cost & Data Report is now a completely different report than the one currently filed with the Medicare program. Information used to complete the report in the past will be insufficient to meet the new reporting requirements. Comments on the second draft of the report are not expected to cause any significant changes in the revised report issued by CMS. Hospices, including provider-based hospices, need to begin internal preparation for the accumulation of the financial and statistical information that will be required. Additionally, hospices need to work closely with those actually preparing the report to strategize to ensure all the information required is being accumulated with the beginning of their applicable cost reporting period.

The Health Group, LLC has been developing initial plans for all of its clients since the first draft of the new report was released in April 2013. These strategies, practice aids, and other cost reporting tools will be shared with attendees at the upcoming educational programs being offered.

On May 12, 2014, the Office of Inspector General (“OIG”) of the Department of Health and Human Services issued a proposed rule updating its regulations for changes made by the Affordable Care Act relating to civil monetary penalties, assessments, and exclusions for certain acts including, but not limited to:

  • Failure to report and return a known overpayment and
  • Making false statements, omissions or misrepresentations in an enrollment or similar application to participate in a federal health care program.

In addition to incorporating the new violations, the proposed rule seeks to clarify the penalty for failure to report and return overpayments by the later of 60 days after the overpayment was identified or the date any corresponding cost report is due, if applicable. The proposed rule also solicits comments regarding the proposed $10,000 per-day penalty for each day a person fails to report and return an overpayment.

The propose rule is continuing evidence of provider’s need to focus on reporting compliance and increased scrutiny on individuals involved in ownership and management of healthcare providers as well as a heightened focus on healthcare fraud enforcement. The proposed rule can be viewed at https://oig.hhs.gov/authorities/docs/2014/fr-79-91.pdf.

The U.S. Centers for Medicare & Medicaid Services (“CMS”) has issued final rules that require hospices to file their own aggregate cap determinations (“CAP”) or have payments suspended in whole or in part until the self-determined CAP computation is filed. Additionally, any self-determined overpayments are to be remitted with the submission.

42 CFR §418.308(c) now reads, “The hospice must file its aggregate payment cap determination notice with its Medicare contractor no later than 5 months after the end of the cap year (that is, March 31st) and remit any overpayment due at that time. Hospices shall file the aggregate cap using data no earlier than 3 months after the end of the cap period. The Medicare contractor will notify the hospice of the final determination of program reimbursement in accordance with procedures similar to those described in §405.1803 of this chapter.

If a provider fails to file its self-determined cap determination with its Medicare contractor within 5 months after the cap year, payments to the hospice will be suspended in whole or in part, until a self-determined cap determination is filed with the Medicare contractor, in accordance with §405.371(e) of this chapter.

The final hospice payment rule for 2015, of which the CAP reporting is one component can be secured at http://www.ofr.gov/OFRUpload/OFRData/2014-18506_PI.pdf. If we can be of assistance to you regarding preparation of the self-determination, estimating of CAP liability, or preparation of a request for Extended Repayment Schedule, please contact us.