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...
MEDICAID HOSPICE PAYMENT RATES UPDATED
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...
TARGETING HOSPICES BY CMS HEIGHTENS
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...
FY 2024 HOSPICE PAYMENTS FINALIZED; RATES INCREASE 3.1%
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...
CMS MODIFIES CALCULATION OF 2022 CAP YEAR LIABILITIES
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...
CMS PLACES NEW HOSPICES IN CALIFORNIA, TEXAS, ARIZONA, AND NEVADA IN ENHANCED OVERSIGHT PROGRAM
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...
HOSPICE INTEGRITY MEASURES PROPOSED IN HOME HEALTH RULE INCLUDING APPLICATION OF 36-MONTH RULE
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...
HIGH-RISK MEDICARE GENERAL INPATIENT SERVICES TARGETED BY CMS
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...
MEDICARE ADMINISTRATIVE CONTRACTOR’S MANAGEMENT OF HOSPICE CAP
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...
2024 PROPOSED HOSPICE PAYMENT UPDATE WILL SIGNIFICANTLY IMPACT HOSPICE PROVIDERS
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...
HOSPICE SPECIAL FOCUS PROGRAM PROPOSAL EXPECTED THIS SUMMER
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...
HOSPICE PROGRAM INTEGRITY – FIRST AND FOREMOST IN THE MIND OF CMS
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...
HOSPICE OWNERSHIP INFORMATION AVAILABLE
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...
CMS RELEASES PROPOSED FY2024 HOSPICE RULE
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...
MEDPAC AGAIN RECOMMENDS CHANGES TO HOSPICE CAP
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...
HOSPICE SELF-DETERMINED CAP LIABILITIES – WHEN IS PAYMENT REQUIRED?
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...
HOSPICE EDUCATIONAL OPPORTUNITIES UPCOMING
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...
CMS RELEASES REVISIONS TO THE HOSPICE SURVEY PROCESS AND SURVEYOR TRAINING
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...
FISCAL YEAR 2023 APPROPRIATIONS BILL
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...
OPPOSE CAP REDUCTIONS IN ANY CONGRESSIONAL ACTION
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...
DON’T FORGET PRF PHASE 4 REPORTING IS UPCOMING
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,...
FY 2023 HOSPICE PAYMENT RATES – QUESTIONS ANSWERED
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 ...
2022 HOSPICE FINANCIAL ACADEMY HIGHLIGHTS
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...
APPLICATION OF SEQUESTRATION TO CAP OVERPAYMENTS RULING ISSUED
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...
CMS RELEASES FINAL HOSPICE RATE UPDATE
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...
HOSPICE ELECTION TO PARTICIPATE IN CMS PART D AND HOSPICE ELECTION PILOT PROGRAM
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...
ASSESSING THE IMPACT OF CAP RECOMMENDATIONS BY MEDPAC
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...
Hospice Alert 22.10
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...
Hospice Alert 22.09
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...
HOSPICE CAP LIABILITY AND CLAIM DENIALS
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...
CMS RELEASES PROPOSED 2023 PAYMENT UPDATE
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...
PRESIDENT SIGNS OMNIBUS SPENDING BILL
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....
MEDICARE PAYMENT ADVISORY COMMISSION (“MedPAC”) ISSUES MARCH 2022 REPORT TO CONGRESS
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%...
Hospice Alert 22.04
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...
CMS MAKES MINOR CHANGES TO HOSPICE COST REPORT
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...
SELF-DETERMINED HOSPICE CAP OVERPAYMENTS
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,...
MEDPAC AND HOSPICE CAP REDUCTION RECOMMENDATIONS
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...
READY FOR CAP REPORTING?
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...
OIG REPORTS ON PALMETTO GBA, LLC CAP MANAGEMENT
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...
CAP HOSPICES NEED TO EXERCISE CAUTION IN REPORTING REVENUES TO SUPPORT THE USE OF PRF FUNDS
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...
NAHC CANCELS 2021 HOME CARE AND HOSPICE CONFERENCE AND EXPO
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...
2021 HOSPICE FINANCIAL MANAGEMENT ACADEMY
Volume 21.13 We are very excited to be sponsoring our Hospice Financial Management Academy live again. The 2021 program will be held at the Paris Hotel and Casino in Las Vegas on September 13-14, 2021. The response to this program has been tremendous. Based on...
2022 HOSPICE PAYMENT RULE RELEASED
Volume 21.12 CMS has issued the final rule, “Medicare Program; FY 2022 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice and Home Health Quality Reporting Program Requirements”. This final rule: Updates the hospice wage...
HOSPICE MERGERS AND ACQUISITIONS CONTINUE AT RAPID PACE
Volume 21.11 Hospices continue to lead the healthcare sector in investor interest and valuation even during the COVID-19 PHE. The price of hospices continues to rise due to the continually increasing demand and return opportunities expected for the next few years....
HOSPICE FINANCIAL MANAGEMENT ACADEMY UPDATE (ROOM BLOCK AND REGISTRATION)
Volume 21.10 The early response to our Hospice Financial Management Academy, scheduled for September 13-14, 2021, has been overwhelming. We have ten (10) remaining spots available for the program (we limit attendance to maximize the benefit of the program). Early...
COULD YOUR HOSPICE OVERPAY A CAP LIABILITY?
Volume 21.09 Recently, we have identified another hospice that has overpaid its CAP liability. This happens when a hospice has claims denied and is also subject to CAP overpayments. When a claim is retroactively denied for a completed CAP Year, the denied claims...
HHS REVISES REPORTING REQUIREMENTS FOR PROVIDER RELIEF FUNDS
Volume 21.08 On June 11, 2021, the U.S. Department of Health and Human Services (“HHS”) revised the reporting requirements for Provider Relief Funds (“PRF”). Key updates include: The period of availability of funds is based on the date the payment is received (rather...
ADVANCE CONFERENCE PROGRAM AVAILABLE
Volume 21.07 The Advance Conference Program and registration information for our upcoming Hospice Financial Management Academy is now available. The program will be held at the Paris Las Vegas Hotel & Casino on September 13-14, 2021. Early registration discounts...
CMS PROPOSES CHANGE IN LABOR COMPONENT OF HOSPICE RATES
As part of the FY 2022 Hospice Payment Rate Update CMS is proposing to modify the labor component for each of the daily reimbursement rates. The labor component is the basis for adjusting payment rates based on the location where the hospice services are furnished....
CMS RELEASED PROPOSED RULE TO UPDATE HOSPICE PAYMENT RATES EFFECTIVE OCTOBER 1, 2021
Volume 21.05 The Centers for Medicare & Medicaid Services (“CMS”) has issued the Proposed Rule, Medicare Program; FY 2022 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice and Home Health Quality Reporting Program...