Volume 24.05 The 2024 Home Health Prospective Payment System (“HH PPS”) Rate Update final rule included a provision clarifying that the definition of a Managing Employee in 42 CFR §424.502 includes the administrator and medical director of a hospice. This change was...
Volume 24.04 LeadingAge, the National Association for Home Care & Hospice (“NAHC”), the National Hospice and Palliative Care Organization (“NHPCO”), and the National Partnership for Healthcare and Hospice Innovation (“NPHI”) have released their National Hospice...
Volume 24.03 In a stunning development, yesterday the U.S. Centers for Medicare & Medicaid Services (“CMS”) announced that the hospice component of the value-based insurance design model (“VBID”) will end on December 31, 2024. The hospice component was recently...
Volume 24.02 As a reminder, hospices must submit their self-determined CAP liability reports on or before February 29, 2024, for the 2023 CAP Year, which ended on September 30, 2023. If the report indicates a liability due to the Medicare program, the liability is to...
Volume 24.01 The U.S. Centers for Medicare and Medicaid Services (“CMS”) has released minor changes to the Hospice Cost & Data Report (“Cost Report”). The changes are as follows: The Cost Report now provides for indication that the filing is a no Medicare...
Volume 23.23 At the December meeting of the Medicare Payment Advisory Commission (“MedPAC”), the only recommendation presented was to eliminate the update to the 2024 Medicare hospice payment rates. A formal vote by MedPAC on the recommendation will occur at the...
Volume 23.22 Yesterday, CMS finalized the Home Health Prospective Payment System Rate Update which includes many provisions impacting hospices. The following provider enrollment regulations were finalized: § 424.502 Definitions. Revises the definition of managing...
Volume 23.21 CMS waived the requirement for hospices to use volunteers (42 CFR §418.78(e)) during the Public Health Emergency (“PHE”); however, the requirement is again effective January 1, 2024. Many hospices had difficulty complying with this requirement even...
Volume 23.20 Most healthcare providers are not eligible for Periodic Interim Payment (“PIP”) reimbursement; however, hospices are eligible. The beginning of a hospice’s fiscal year is the perfect time to request PIP reimbursement in lieu of being reimbursed as claims...
Volume 23.19 CMS has posted those plans that will be participating in the Medicare Advantage Value-Based Insurance Design Model in 2024, including those participating in the Hospice Benefit Component. There will be less Hospice Benefit Component participation in 2024...
Volume 23.18 The U.S. Centers for Medicare & Medicaid Services has updated Medicare hospice payment rates effective October 1, 2023. Although not consistent with Medicare payment rates, the rates are calculated based on established Medicare rates. Rates, subject...
Volume 23.17 Yesterday the Centers for Medicare and Medicaid Services (“CMS”) reported that nearly 400 hospices are being considered for potential administrative action. This is the result of site visits to numerous hospices. The site visits are the result of...
Volume 23.16 On July 28, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a final rule (CMS-1787-F) that updates Medicare hospice payments and the aggregate CAP amount for fiscal year (FY) 2024 in accordance with existing statutory and regulatory...
Volume 23.15 ]On July 20, 2023, CMS instructed the Medicare Administrative Contractors (“MACs”) to modify the calculation of hospice CAP liabilities for the 2022 CAP Year. The modified calculation will be made to appropriately apply sequestration for the 2022 CAP...
Volume 23.14 Effective today, July 13, 2023, CMS has placed new hospices, defined below, in a provisional period of enhanced oversight. A new hospice is defined as: A new enrollee in the Medicare program on or after July 13, 2023, A hospice submitting a change of...
Volume 23.13 We have been continuously reporting on the numerous hospice provider integrity measures being considered. CMS is now proposing as part of the Calendar Year (CY) 2024 Home Health (HH) Prospective Payment System Rate Update numerous hospice integrity...
Volume 23.12 In June 2023, the U.S. Department of Health and Human Services, Office of Inspector General (“OIG”) has added the “Audit of Selected, High-Risk Medicare Hospice General Inpatient Services” to the OIG Work Plan. According to the Work Plan addition, “GIP...
Volume 23.11 We previously reported on the OIG Report (2021) related to Palmetto GBA’s management of the hospice CAP report and overpayment collection activities. In that report, CMS identified CAP overpayments totaling $545,639 not collected and $17,513 of refunds...
Volume 23.10 Under the proposed hospice payment rule, payments to hospices for the year beginning October 1, 2023, will increase by only 2.8%. This increase in base rates, adjusted by geography, is not close to the overall increase in the cost of services being...
Volume 23.09 The Consolidated Appropriations Act (CAA) of 2021 authorized the Secretary of Health & Human Services to create a Special Focus Program (SFP) which aims to address issues that place hospice beneficiaries at risk for poor quality of care through...
Volume 23.08 The 2024 Proposed Hospice Rule is only one indicator of the increased focus by CMS and federal legislators on hospice program integrity. CMS, in the 2024 Proposed Rule, has reported significant information regarding hospice utilization trends and other...
Volume 23.07 The U.S. Department of Health and Human Services (“DHHS”) is releasing information on the ownership of over 6,000 hospices and 11,0000 home health agencies certified to participate in the Medicare program on the Centers for Medicare & Medicaid...
Volume 23.06 On Friday, March 31, 2023, the Centers for Medicare & Medicaid Services issued the proposed rule, Medicare Program; FY 2024 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice Quality Reporting Program...
Volume 23.05 According to the March Report to Congress, “Based on the generally positive indicators of payment adequacy and strong margins, the Commission concludes that a reduction to aggregate payments is warranted. However, in this sector, with the range of...
Volume 23.04 There is substantial confusion regarding when overpayments determined by self-determined CAP liability filings are required to be paid. The regulations are clear that any CAP liability determined by self-filing is due at the time of filing; however, in...
Volume 23.03 It is not too early to plan for and schedule your educational plan for 2023. As the COVID-19 Public Health Emergency comes to an end, many regulatory changes are already occurring and many more are forthcoming. Additionally, as integrity issues take...
Volume 23.02 Revisions to Appendix M of the CMS State Operations Manual have been released. The revisions are effective immediately; however, state survey directors have thirty (30) days to communicate the changes. State surveyors and accrediting organizations must...
Volume 23.01 The Fiscal Year 2023 Appropriations Bill (“Omnibus Budget”) recently passed includes the following of immediate interest to hospice providers: Sequestration – The legislation extends Medicare sequestration into 2032 and sets the sequestration at two...
Volume 22.17 All hospice providers need to be vocal regarding any efforts that Congress may take to reduce the Medicare CAP as part of any end-of-year legislative package. The National Association for Home Care and Hospice (“NAHC”) has created a simple email for you...
Volume 22.16 Many providers received Phase 4 funding (payment received between July 1, 2021, and December 31, 2021) of more than $10,000. These funds are used for lost revenues and qualifying COVID-19 expenses incurred between January 1, 2020, through December 31,...
Volume 22.15 FY 2023 hospice payment rates, effective October 1, 2023, have been set. Routine home care rates are as follows, before any wage index adjustment based on the location of the patient: FY 2023 Hospice RHC Payment Rates Code Description ...
Volume 22.15 We are very excited as we finalize our plans for the upcoming 2022 Hospice Financial Management Academy to be held on September 19-20, 2022. We are thrilled to be back at the Hotel Monteleone in New Orleans and look forward to seeing many clients and...
Volume 22.14 Recently, the United States Court of Appeals for the Ninth Circuit ruled that the way Medicare payments and sequestration was being handled when a hospice exceeds the hospice CAP was appropriate. The Health Group, LLC has previously reported that the...
Volume 22.13 The U.S. Centers for Medicare & Medicaid Services (“CMS”) has released the final rule updating the Medicare hospice payment rates and aggregate CAP amount for FY 2023, which begins on October 1, 2022. The FY 2023 hospice payment update percentage is...
Volume 22.12 Hospices can sign-up to participate in the CMS Part D and Hospice Election Pilot Program through July 31, 2022. The primary focus of the Pilot Program is the acceleration of communications and notifications between the Hospice, Medicare Part D Plans, and...
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...
IRS INCREASES ALLOWABLE MILEAGE REIMBURSEMENT Effective July 1, 2022, the standard mileage rate for business travel has been increased to 62.5 cents per mile, an increase of 4 cents from the current allowable reimbursement rate. This increase, mid-year, is in...
Volume 22.09 CLARITY IN CAP LIABILITY PROVISIONS OF PURCHASE AGREEMENTS As more hospices exceed hospice aggregate payment limitations (“CAP”) and hospice acquisitions continue at a rapid pace, we are constantly becoming involved in disputes between the Buyer and the...
Volume 22.08 As hospices become subjected to claims denials, whether such denials are the result of a UPIC or not, the hospice may be entitled to a refund of previously paid CAP liabilities. We reported on this in 2021; however, The Health Group, LLC ("THG") recently...
Volume 22.07 Yesterday, March 30, 2022, CMS issued the proposed rule that would update Medicare hospice payment rates and the aggregate payment limitation (“CAP”) effective October 1, 2022. 2022-07030.pdf (federalregister.gov). The proposed rate increase in Medicare...
Volume 22.06 Last week President Biden signed into law a $1.5 trillion spending package, referred to as an “Omnibus Spending Bill”. The legislation will fund the government through September 2022. The Bill also provides significant financial assistance to Ukraine....
Volume 22.05 MedPAC has released its March 2022 Report (“Report”) to Congress. As expected, MedPAC has again recommended hospices not receive any payment update in 2023 and that the aggregate payment limitation (“CAP”) be wage adjusted and reduced by an arbitrary 20%...
Volume 22.04 TECHNICAL CORRECTION Our last Hospice Alert (Volume 22.03) indicated that CMS revised the Hospice Cost & Data Report on September 25, 2022. The actual date of the revision was February 25, 2022, and is available here. HOSPICE CAP OBSERVATIONS...
Volume 22.03 On September 25, 2022, CMS revised the Hospice Cost & Data Report to add a new non-reimbursable cost center to accumulate costs associated with suicide accomplished with aid of a physician in those states that allow assisted suicide. Federal funds...
Volume 22.02 According to MedPAC, almost 20% of all hospice providers are now exceeding the Medicare aggregate payment limitation (“CAP”). Many hospices will have a CAP liability when they file their self-determined CAP liability report on or before February 28,...
Volume 22.01 The Medicare Payment Advisory Commission (MedPAC) is an independent congressional agency established by the Balanced Budget Act of 1997 (P.L. 105-33) to advise the U.S. Congress on issues affecting the Medicare program. In addition to advising the...
Volume 21.17 Medicare- certified hospices are required to self-report the calculated aggregate payment limitation (“CAP”) no earlier than three (3) months after, and no later than five (5) months after the end of the hospice CAP Year. The 2021 CAP Year runs from...
Volume 21.16 The U.S. Department of Health & Human Services (“DHHS”) Office of Inspector General (“OIG”) issued a Report in July 2021 regarding the CAP management process of Palmetto GBA, LLC (“Palmetto”). Palmetto was selected from the Medicare Administrative...
Volume 21.15 Many hospices incur CAP liabilities, which must be repaid to the Medicare program. Information provided by HRSA regarding lost revenues does not specifically address CAP overpayments; however, HRSA Q&A includes the following: “Provider Relief Fund...
Volume 21.14 Yesterday the National Association for Home Care & Hospice announced the cancellation of the upcoming 2021 Home Care and Hospice Conference and Expo, which was scheduled for October 3-5, 2021, in New Orleans. “This was a very difficult decision to...