Volume 24.16
Many hospices have experienced claim rejections resulting significant cash-flow disruptions because of reporting the certifying physician which did not match information in the Provider Enrollment, Chain and Ownership System (“PECOS”) Enrolled Physicians File. Claims rejected relate to claims with “From” dates on or after June 3, 2024.
National Government Services (“NGS”) has released news regarding these rejections indicating that corrections are expected November 18, 2024. Hospice Claim Report (Update), Reason Code 17729, indicates that a hospice claim was denied because the physician is not enrolled or opted-out to certify hospice claims in Medicare.
Palmetto released information which is available here. CGS information is available here.
CMS PROCEEDING WITH IMPLEMENTATION OF HOSPICE SPECIAL FOCUS PROGRAM
The Hospice Special Focus Program (“SFP”) was established by CMS to identify those hospices having problems complying with quality standards and to improve their performance. However, the industry has numerous concerns with underlying data and, potentially, targeting inappropriate hospices for the program.
Bipartisan bill H.R. 10097 has been introduced to delay implementation of SFP; thereby, allowing time to address problems with the program. The Alliance has created a link where hospices can contact their federal legislators of the program and request their assistance regarding this matter here.
UPCOMING CAP REPORTING
Hospices must file their self-determined CAP liability report to their respective Medicare Administrative Contractor (“MAC”) on or before February 28, 2025, for the CAP Year ended on September 30, 2024.
We recommend the following:
1. Make certain you have up-to-date access to PS&R data required to complete the self-filing.
2. Secure Medicare payments and beneficiary counts from the PS&R System for the CAP Year ended September 30, 2024, at the earliest opportunity after January 1, 2025. This will ensure that any liability is minimized at the time the self-filing is submitted.
3. If you do not have a CAP liability, file the self-filing immediately.
4. If you have a CAP liability, the self-filing can be made at or near February 28, 2025.
5. If you have a CAP liability and intend to request an Extended Repayment Schedule (“ERS”), begin preparing the financial information for the ERS request.
6. If you have a CAP liability, the MACs will issue a repayment demand. At that time, the liability can be paid or the ERS request submitted.
7. If you have a CAP liability or expect a CAP liability will eventually occur, identify procedures for tracking the growth of the liability.
8. If you have a CAP liability or expect a CAP liability will eventually occur, consider estimating or having an estimate made of the ultimate CAP liability (expected repayment) that will occur over the next several years. This is important for financial statement reporting and cash flow considerations.