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Volume 21.01

We continually receive questions regarding Medicare enrollment revalidations.  CMS has temporarily ceased revalidation efforts for all Medicare providers or suppliers.  During the public health emergency, CMS will not issue any new revalidation notices, deactivate providers who fail to respond to revalidation requests, or update the Medicare Revalidation Tool with new revalidation due dates.  The last dates posted were those due on or before September 30, 2020.

Revalidation applications submitted to your MAC will continue to be processed but not in an expedited manner. Upon the lifting of the public health emergency, CMS will resume revalidation activities.


Self-determined CAP Report submissions are due on or before March 1, 2021 for the 2020 CAP Year, which ended on September 30, 2020.  The following are important:

  • Secure PS&R data at the earliest date on or after January 1, 2021 to potentially minimize any CAP liability that needs to be paid at this time.
  • CGS has reported that The Centers for Medicare & Medicaid Services (CMS) has made a change to include/add the ACO Demonstration Reduction amount from the PSR summary report to the Reimbursement amount used to calculate the Hospice Cap determinations. ACO Demo Reduction can be found under Post-Sequestration Demo Reduction line of the PSR Summary report. (see below for example).

  • Remember that the self-determined CAP Report submission is not truly indicative of any CAP liability that currently exists, net reimbursement plus post-sequestration demo reduction.  Gross reimbursement will be used in the final determination of the CAP liability.  Post-sequestration demo reductions (payment reductions) are directly reported by patient on remittance advices received by the hospice.  Hospices should carefully review the propriety of these demo reductions as they are considered payments in the determination of CAP liability.
  • The Medicare Administrative Contractors (“MAC”) review CAP liabilities differently and on different schedules.  The hospice will receive a demand for repayment from the MAC at the time of their review.


The Health Group, LLC is tentatively planning to hold a live Hospice Financial Management Conference in the Fall of 2021.  The 2020 program was cancelled due to the COVID-19 PHE.  We recognize that such plans need to be flexible; however, we appreciate any thoughts regarding the program including whether or not, at this time, you would consider travel, subject matter for consideration (so much has changed), and locations you would prefer if travel is possible and desired.  Please send comments to contact@healthgroup.com.