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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 are processed.  Many hospices are unaware of the availability of PIP reimbursement which provides fixed bi-weekly payments to the hospice throughout the year, with periodic adjustment to the PIP payment rates based on actual billing experience and projected levels of Medicare beneficiary activity.

Requesting PIP reimbursement is easy and, once approved, management and periodic reporting to the Medicare Administrative Contractor is relatively simple.  PIP can accelerate cash flow to the hospice if properly monitored, provides reimbursement stability (same amount every two weeks, adjusted three (3) times per-year), and generally requires minimal administrative resources.

Assuming level utilization throughout the year, a hospice with $2,000,000 in total Medicare reimbursement would experience approximately $49,000 more in their bank account daily than the hospice would experience being reimbursed as claims are processed (assuming all claims are reimbursed within thirty days of the end of the prior month).  Attendees at our upcoming conference will be provided with detailed information to take back to their hospices to appropriately assess the potential cash-flow benefits of PIP. 


Four members of Congress sent a bipartisan letter to CMS and the Office of Management and Budget (OMB) expressing their concerns with CMS’ proposed design for the hospice special focus program (SFP).  They ask that CMS go back and work with the SFP Technical Expert Panel (TEP) of outside experts to address the limitations of the currently proposed SFP algorithm before publicly launching the program.  Additionally, they request that CMS test the modified SFP before full implementation allowing hospices to assess how they perform and rank.  Hospices need to support this effort to delay the full implementation of SFP. 


OIG maintains a list of all currently excluded individuals and entities called the List of Excluded Individuals/Entities (“LEIE”). Anyone who hires an individual or entity on the LEIE may be subject to civil monetary penalties (“CMP”). To avoid CMP liability, health care entities should routinely check the list to ensure that new hires and current employees are not on it.  The list should also be reviewed to ensure that vendors are not included on the list.  We recommend all healthcare providers review employees and vendors against the list at the beginning of the year.  The list is available here 


The Health Group, LLC’s 2023 Hospice Financial Management and Administration Conference 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.  The program also includes follow-up information on the Employee Retention Credit and final Provider Relief Fund reporting.

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.   If you have a problem, please call the hotel.