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Volume 22.11

The Health Group, LLC constantly monitors recommendations of the Medicare Payment Advisory Commission (“MedPAC”) to Congress.  A significant recommendation of MedPAC relating to hospice reimbursement is to reduce the Medicare hospice CAP by twenty percent (20%) and to adjust the CAP geographically, consistent with the wage index applicable to hospice payment rates.

We have continuously supported adjusting the CAP based on geographical location of the hospice.  However, any wage adjustment to the CAP should be phased in to minimize the short-term impact on rural providers that would be negatively impacted.  Additionally, the wage adjustment is best applied at the hospice location and not the individual patient location.  Hospices do not have multiple wages based on the location of the patient.  Rather, wages are generally constant for personnel.

Likewise, we have continually been opposed to an arbitrary reduction to the CAP (recommended at 20%) as such an adjustment is not based on any underlying basis other than penalizing hospices serving patients with longer lengths-of-stay, even if those patients meet the requirements to receive hospice care and reducing overall hospice expenditures.  We also believe that MedPAC’s estimates of the impact on hospice providers of the 20% reduction are understated.

The Health Group, LLC serves hundreds of hospices across the country.  Most of these hospices prepare their own self-reporting CAP liability report, which is due five (5) months after the end of the CAP Year.  However, for the 2021 CAP Year we prepared one hundred thirteen (113) self-determined CAP liability filings for our clients.  Using the 113 hospices as the basis of assessing the impact of the MedPAC recommendations, we have estimated that 48.7% of the 113 hospices would exceed the CAP and that the CAP liability is estimated at 7.08% of the Medicare payments to these hospices.  The estimates are far in excess of the estimates by MedPAC.

We recognize that the 113 hospices were not randomly selected from the entire population of hospices; however, other attributes of these hospices validate our concerns regarding the MedPAC recommendations.  A copy of our report, “Medicare Hospice Aggregate Payment Limitation and MedPAC’s Recommendations for Modifying the CAP” is available at Special-Report-Assessing-MedPAC-CAP-Recommendations.


The 2022 Hospice Financial Management Academy is scheduled for September 19-20, 2022, at the Hotel Monteleone in New Orleans.  The program includes coverage of many financial and issues of importance to hospices, including Medicare Advantage inclusion, claim review processes, CAP, new focus of Medicare enrollment and revalidation, PIP for hospice providers, and changes to and enhancement of hospice cost reporting.  Up-to-date information, as available, and registration is available here.  We look forward to seeing you or someone from your organization in New Orleans.  Space is limited.  Early registration discounts and substantially discounted hotel rates are available.


On June 14, 2022, CMS issued instructions regarding “Surveys for compliance with Omnibus COVID-19 Health Care Staff Vaccination Requirements”, available at Surveys for compliance with Omnibus COVID-19 Health Care Staff Vaccination Requirements (cms.gov).  The requirements have been relaxed.  Since the vaccination requirements became effective, 95% of the nearly 12,000 providers that have been surveyed by states are in compliance with the requirements.