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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 follow the new survey process as well as utilize updated interpretative guidance.  Details are available at Revisions to Hospice-Appendix M of the State Operations Manual and the Hospice Basic Surveyor Training (cms.gov).


Although the COVID-19 Public Health Emergency (“PHE”) is coming to an end, many hospices received Phase 4 Provider Relief Funding.  Phase 4 funding is defined as general or targeted funding and/or American Rescue Plan Rural Payments.  Funding received between July 1, 2021, and December 31, 2021 in excess of $10,000 requires reporting on the use of those funds.  The reporting portal is now open, and reporting must be completed and submitted on or before March 31, 2023.  Additional information is available at https://www.hrsa.gov/provider-relief/reporting-auditing.


Don’t forget that your Provider Self-Determined Aggregate CAP Limitation (“CAP Report”) must be filed with your Medicare Administrative Contractor (“MAC”) on or before February 28, 2023.  Failure to report timely may result in a suspension of Medicare payments,


Hospices should know the importance of the cost report submission.  CMS has used cost report data to rebase hospice payments as well as modify the labor component for each level of service (used in the determination of payment rates) based on this report.  The following are high-level issues relating to the preparation and accuracy of the cost report:

  • Cost reports must be prepared on an accrual basis.  Even if your tax return is prepared on a cash basis, cash basis cost reports are not acceptable submissions.
  • Cost reports should be reconciled to tax return submissions and financial statements to ensure consistency of financial information.  Variances between financial statements prepared by external CPAs, whether compiled, reviewed, or audited, are to be reconciled and the reconciliation submitted with the cost report.
  • All related party transactions are to be reported in the cost report and costs adjusted to the costs incurred by the related party unless the Hospice is eligible for an exception.
  • Don’t miss the reporting deadline.  Failure to report timely will result in a suspension of Medicare payments.