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Volume 24.01

The U.S. Centers for Medicare and Medicaid Services (“CMS”) has released minor changes to the Hospice Cost & Data Report (“Cost Report”).

The changes are as follows:

  • The Cost Report now provides for indication that the filing is a no Medicare utilization filing, if applicable.
  • Effective beginning January 1, 2024, hospice accounting records should segregate the costs of marriage and family therapy services and mental health counseling services.  These costs are to be reported with other counseling services (line 36 of Worksheets A-1, A-2, A-3, and A-4).
  • Cost Report Level 1 Edit – Worksheet S must identify the cost report submission as a full, low, or no utilization filing.
  • Cost Report Level 2 Edit – Worksheet A, column 7, line 2 (Capital-Related Costs – Movable Equipment) must include a cost entry more than $0.

The Cost Report cannot be submitted electronically if the report contains any Level 1 Edits.


Hospices are reminded that the self-determined CAP liability filings are due on or before February 29, 2024, for the 2023 CAP Year which ended on September 30, 2023.

If the filing indicates a CAP liability, the liability must be liquidated at the time of the filing, or a Request for Extended Repayment Schedule (“ERS”) must be filed at the same time as the filing.

Remember, if the self-determined CAP liability filing does not indicate a CAP liability, it is still possible to incur a liability because patient beneficiary counts decline as services continue to be provided to patients who were served during the 2023 CAP Year.  The 2023 CAP Year liability calculations will be reviewed and revised by the Medicare Administrative Contractor (“MAC”) at least annually until the CAP Year is closed.

Hospices should be tracking any CAP liability, or potential CAP liability, continuously.


The Medicare Payment Advisory Commission (“MedPAC”) will be recommending no increase in Medicare reimbursement rates to hospices beginning October 1, 2024.

MedPAC appears to be backing off its previous recommendations for reducing the CAP by 20% and wage-adjusting the CAP.  We are pleased to see MedPAC not recommend an arbitrary reduction to the CAP; however, we believe wage-adjusting the CAP is necessary to reverse the inappropriate CAP liability calculation caused by the current calculation which discriminates against hospices based on geographical location.

MedPAC will release its annual report to Congress in March.