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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 Year to the calculated CAP liabilities.  CAP liabilities are reduced by sequestration applicable to the payments by which the CAP was exceeded.

Sequestration for the 2022 CAP Year was as follows:

  • 0% for October 1, 2021, through March 31, 2022, claims,
  • 1% for April 1, 2022, through June 30, 2022, claims, and
  • 2% for July 1, 2022, through September 30, 2022, claims.

Requirements for calculation as provided to the MAC are that the MACs shall request the Provider Statistical and Reimbursement (PS&R) report needed to calculate the 2022 hospice CAP determination for the following bracket periods:

  • October 1, 2021, to March 31, 2022, service payments,
  • April 1, 2022, to June 30, 2022, service payments, and
  • July 1, 2022, to September 30, 2022, service payments.

CMS provided a template for the calculation; however, the template requires certain corrections to arrive at the proper calculation assigning any CAP overpayment to the appropriate period for calculating the sequestration add-back based on our conversations with one of the MACs.  Instruction provided to the MAC are located here.

The recalculation does not attempt to identify beneficiaries in the three (3) separate periods.  It only attempts to determine the amount of the sequestration add-back against CAP liabilities at 2%, 1%, or 0%.  We do not expect significant changes in the final determination of the 2022 CAP Year liability for most providers; however, some hospices may be impacted if the CAP liability for the 2022 CAP Year, before sequestration add-back, exceeds payments received for services rendered for the period of July 1, 2022, through September 30, 2022.  Recalculations of any 2022 CAP liability by the MAC should be carefully reviewed by the hospice to ensure appropriate calculation consistent with the intent of the instructions provided to the MACs.


The Health Group, LLC’s 2023 Hospice Financial Management and Administration Conference is rapidly filling up (attendance limited).  The program will be held at the beautiful Lago Mar Beach Resort, Fort Lauderdale, Florida on November 9-10, 2023.  Program information, including registration information, is available here.  The program provides for a special session on the financial implications of the many hospice integrity initiatives, both implemented and proposed.

We are encouraging anyone who expects to attend to make room reservations at their earliest opportunity.  Many individuals planning on attending the program have already reserved their rooms.  The Lago Mar Beach Resort will sell out for the days of our conference.  Special rates have been secured with the Lago Mar Beach Resort & Club; however, to secure these rates, call (855) 829-2923 and inform the hotel that you are attending “The Health Group, LLC Hospice Financial Administration Conference” or online at www.lagomar.com.

When making reservations online, go to reservations, click on group code, and enter 2311THEHEA.  Select the dates you will be staying, even if the dates are indicated as not available, select them and your room type.  All attendees are being offered Executive One Bedroom Suites at $235/night.  Resort fees have been waived for our attendees.  If you have a problem, please call the hotel.  The hotel is making the $235/night available for two (2) days prior and two (2) days after the program dates.