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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, 2022.

The use of these funds must be reported between January 1, 2023, and March 31, 2023.

All providers should be accurately accounting for revenues at least quarterly and continue to track expenses that would not have been incurred except for the COVID-19 PHE.  Providers should be preparing for the submission to HRSA as there is limited time once the qualifying period has ended until the required reporting date.


The 2022 CAP Year ended on September 30, 2022.  All hospices must file their self-determined CAP (“CAP Report”) for the 2022 CAP Year between January 1, 2023, and February 28, 2023.  Tips relating to CAP reporting include the following:

  • Secure beneficiary counts and payments for the 2022 CAP Year as soon as possible on or after January 1, 2023.  This will ensure that the hospice reports the lowest CAP liability, if one exists, at the time of self-filing.
  • Even though the hospice secures data at or near January 1, 2023, the CAP Report does not need to be filed until February 28, 2023.
  • If the CAP Report indicates a liability due to the Medicare program, early preparation of the CAP Report will better prepare the hospice for any liability which needs to be paid based on the self-filing.
  • If the hospice will be reporting a CAP liability and needs to secure an Extended Repayment Schedule (“ERS”) to repay the liability, the hospice will need to begin accumulating the information needed to apply for an ERS.  This includes up-to-date financial information through December 31, 2022.
  • Terminated providers should file their final CAP Report on or before February 28, 2023, if they terminated Medicare participation and the termination has been processed.
  • Visit the respective website of the servicing Medicare Administrative Contractor (“MAC”) regarding calculated overpayments and making repayments.  The instructions issued by the MACs are not consistent.
  • Remember, the MAC will recalculate the CAP liability or potential CAP liability annually for at least three (3) years.  Even if you do not report a liability at the time of self-filing, the hospice may experience a liability for the 2022 CAP Year later.  If you will be self-reporting a CAP liability, or if the margin between the calculated CAP and Medicare payments for services rendered during the CAP Year is insignificant, the hospice may need to make estimates of the ultimate CAP liability for financial statement, PRF reporting, or other purposes.
  • Retain a copy of all submissions and correspondence between the hospice and the MAC relating to the CAP.