Volume 25.02
Implementation of the highly controversial hospice Special Focus Program (“SFP”) has been suspended by the Trump Administration.
SFP, which was part of the 2024 home health payment rule, was intended to identify poor performing hospices and effect quality improvement. Failure on behalf of selected hospices to improve would result in penalties.
The hospice industry has largely contended that the program itself was significantly flawed including the selection of those hospices that would have been required to participate. The decision to suspend SFP is welcomed by the hospice industry.
The program was halted effective February 14, 2025, see here.
CAP IMPACT OF PATIENTS PREVIOUSLY SERVED UNDER HOSPICE BENEFIT COMPONENT OF VBID
We continue to get numerous questions regarding the CAP impact of patients who were served through December 31, 2024, under the hospice benefit component of the Value-Based Insurance Design Model (“VBID”).
Under Original Medicare, hospice providers are subject to two payment caps—one for inpatient care, and another for aggregate payments. The number of days of inpatient care a hospice provider furnishes is limited to not more than 20% of total patient care days. The hospice aggregate cap amount limits payments to a hospice provider to the cap amount (updated annually by CMS pursuant to 42 CFR 418.309) multiplied by the number of Medicare patients served. Of importance, Model-participating MAOs’ enrollees’ hospice experience will not be included in either payment cap calculation. In CY 2025, Medicare retains responsibility for the hospice coverage and the payment caps will apply to previous VBID patients who are now traditional Medicare patients.
Patient days provided and payments made to the Hospice while the patient was part of the VBID model are not considered in the calculation of a specific hospice’s CAP liability. These patients, while participating in the hospice benefit component of VBID are treated as if they were private insurance patients.
Additional details are available here.
THE CREDIT BALANCE REPORT IS NO LONGER A MANDATORY QUARTERLY FILING
Effective December 31, 2024, Medicare providers, including hospices, are no longer required to submit the Medicare Credit Balance Report (CMS-838) on a quarterly basis. However, all providers are still required to self-report identified overpayments and submit a credit balance report when such overpayments occur.
The Medicare Credit Balance Report is available here.