Volume 25.10
The Office of Inspector General, Department of Health and Human Services (“OIG”) has completed its audit of all three hospice Medicare Administrative Contractors (“MACs”) regarding the calculation of hospice CAP liabilities and the collection of monies owed to the Medicare program. The audit reports are available as follows:
CGS: Here.
Palmetto GBA: Here.
NGS: Here.
The CGS report is the last to be completed. The OIG recommended to CGS that it should:
- Discontinue its practices that limit the reopening of prior year’s CAP calculations and start reopening all prior year’s CAP calculations.
- Revise it policies and procedures so that it meets the reopening deadlines established in the federal requirements.
- Conduct the prior year’s hospice CAP calculations for the five (5) hospices with UPIC recoupments and collect any additional overpayments.
The previous report directed at Palmetto GBA provided the following recommendations:
- Collect the $545,639 in lookback payments and return $17,513 in lookback refunds resulting from 2017 hospice CAP calculations for lookback years.
- Discontinue the internal policies of waiving certain overpayment collections related to lookback years and start collecting all hospice CAP overpayments and paying refunds in accordance with CMS requirements.
- Develop processes for communications between the departments directly and indirectly involved in hospice CAP oversight.
In the OIG report directed at NGS, the following were recommended:
- Collect $2,160,587 in lookback overpayments and return $22,576 in lookback refunds resulting from 2019 hospice CAP calculations for lookback years.
- Discontinue its internal policy of waiving overpayment collections related to lookback years and start collecting hospice CAP overpayments and paying refunds in accordance with CMS requirements (same as Palmetto recommendation).
- Change its instructions on the CAP determination notices to follow the CMS requirement that hospices remit overpayments at the time they submit their CAP determination notice.
OIG ISSUES REPORT ON TEXAS HOSPICE CAP COLLECTIONS
This month, the OIG released its report, “Texas Did Not Calculate or Collect Hospice CAP Overpayments Totaling $10.5 Million”. CMS’s State Medicaid Manual (“Manual”) states that a State may limit aggregate payments made to a hospice during a hospice CAP period. Yes, the CAP may be applicable to Medicaid beneficiaries in addition to Medicare beneficiaries. In the OIG report the Texas Health and Human Services Commission was recommended to:
- Collect the hospice CAP overpayments totaling $10,498,423 and refund the federal share of $6,916,454 to the federal government.
- Develop and implement policies and procedures related to calculating hospice CAP overpayments.
The entire OIG report is available here.
An entire afternoon at our upcoming educational program is devoting to drilling down into hospice CAP and the many circumstances surrounding calculation, repayment demands, and options available to hospice providers.
A COUPLE SPOTS REMAIN AVAILABLE FOR THE UPCOMING HOSPICE FINANCIAL ADMINISTRATION CONFERENCE
Only a couple spots remain for the upcoming 2025 Hospice Financial Administration Conference scheduled for October 16-17, 2025, at the Hilton Orlando Lake Buena Vista – Disney Springs Area. The hotel is within walking distance from Disney Springs and shuttle service to the Disney properties is included with your reservation.
An additional session is now on the schedule dealing with the hospice revenue cycle. The program offers an expanded breakout Hospice CAP session and cost report session in response to requests by previous attendees. Significant attention is also provided regarding integrity and expanding claims audits processed. As always, space is limited at our programs to provide for more interactive discussions intended to meet your educational needs.
The program agenda, hotel reservation link, and registration information are available here. On Thursday, October 16th we will be offering a short reception immediately after the conclusion of the program. This is a fantastic opportunity to network with other attendees. If you have any questions regarding the program, do not hesitate to reach out to us.
We look forward to seeing you in Orlando.