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Volume 23.11

We previously reported on the OIG Report (2021) related to Palmetto GBA’s management of the hospice CAP report and overpayment collection activities. In that report, CMS identified CAP overpayments totaling $545,639 not collected and $17,513 of refunds due to hospices not repaid. In that report, CMS also recommended that the overpayments be collected, refunds be issued, and Palmetto GBA discontinue its practice of waiving certain CAP liability collections. Palmetto GBA concurred with the recommendations and agreed to take actions to address the recommendations of CMS.

In November 2022, the OIG prepared a similar report on the hospice CAP management practices of National Government Services (“NGS”). The OIG identified $2.1 million of CAP liabilities not being pursued by NGS due to the lookback policies of NGS. Additionally, because NGS instructed hospices to wait to submit self-reported overpayments until a demand letter was issued, substantial CAP recoveries were delayed causing the government to lose the benefit of the repayment for more than two (2) months.

CMS recommended NGS to pursue collection of the $2.1 million in overpayments, discontinue the practice of waiving certain overpayments due to its internal policies, and change it’s instructions on the CAP determination notices to follow CMS’s requirement that hospices remit overpayments at the time they submit their CAP determination notice.

Interestingly, NGS agreed to begin collecting overpayments at the time of the self-filing by hospices; however, NGS did not concur with the recommendation regarding the outstanding lookback policies as recommended by CMS.

NGS serves approximately the same number of hospices as does Palmetto GBA; however, the hospices served by NGS have approximately three (3) times the CAP liability, in the aggregate, as those served by Palmetto GBA.

The OIG reports can be secured at the following locations: Palmetto and NGS.


The Health Group, LLC is accepting registrations for the 2023 Hospice Financial Management and Administration Conference. Many registrations have already been received and the program is expected to sell out (attendance, as always, is limited to better ensure the quality of the program). The program will be held at the beautiful Lago Mar Beach Resort, Fort Lauderdale, Florida on November 9-10, 2023. For 2023 we are focusing on prospective financial and compliance issues of hospices, while still addressing retrospective reporting issues. This is especially important now as CMS and federal legislators are focusing on integrity as evidenced by the proposed rules for FY2024. Program information, including registration information, is available here.

We are encouraging anyone who expects to attend to make room reservations at their earliest opportunity. Many individuals planning on attending the program have already reserved their rooms. The Lago Mar Beach Resort will sell out for the days of our conference. 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 https://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. All attendees are being offered Executive One Bedroom Suites at $235/night. Resort fees have been waived for our attendees. If you have a problem, please call the hotel. The hotel is making the $235/night available for two (2) days prior and two (2) days after the program dates.