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News Alerts

REPAYMENT AND RECOVERY OF COVID-19 CAAP

 Volume 22.09 In March 2021, CMS began recovering COVID-19 Accelerated and Advance Payment (“CAAP”) balances.  After one year, the recovery of the advanced monies was made at twenty-five percent (25%) over eleven months, followed by fifty ...

FY 2023 HOSPICE PAYMENT RATES – QUESTIONS ANSWERED

 Volume 22.15 FY 2023 hospice payment rates, effective October 1, 2023, have been set.  Routine home care rates are as follows, before any wage index adjustment based on the location of the patient: FY 2023 Hospice RHC Payment Rates  Code  ...

YOUR ASSISTANCE NEEDED TO COMBAT MEDICARE PAYMENT REDUCTIONS FOR HOME HEALTH

Volume 22.04 The National Association for Home Care & Hospice (“NAHC”) needs the industry to be vocal regarding the CY 2023 Medicare home health services Proposed Rule, which includes 2023 payment rates and a variety of other ...

2022 HOSPICE FINANCIAL ACADEMY HIGHLIGHTS

Volume 22.15 We are very excited as we finalize our plans for the upcoming 2022 Hospice Financial Management Academy to be held on September 19-20, 2022.  We are thrilled to be back at the Hotel Monteleone in New Orleans and look forward to ...

OIG EXCLUSION LIST UPDATED

Volume 22.08 The Office of Inspector General (“OIG”) has the authority to exclude individuals and entities from Federally funded health care programs pursuant to section 1128 of the Social Security Act ("Act") (and from Medicare and State ...

CMS REVALIDATION LIST MAY NOT BE UP TO DATE

Volume 22.07 Medicare providers are required to revalidate information contained in the Medicare enrollment records on a periodic basis to ensure all information on file is accurate and compliant with Medicare regulations. Revalidation ...

APPLICATION OF SEQUESTRATION TO CAP OVERPAYMENTS RULING ISSUED

Volume 22.14 Recently, the United States Court of Appeals for the Ninth Circuit ruled that the way Medicare payments and sequestration was being handled when a hospice exceeds the hospice CAP was appropriate.  The Health Group, LLC has ...

CMS RELEASES FINAL HOSPICE RATE UPDATE

Volume 22.13 The U.S. Centers for Medicare & Medicaid Services (“CMS”) has released the final rule updating the Medicare hospice payment rates and aggregate CAP amount for FY 2023, which begins on October 1, 2022. The FY 2023 hospice ...

DEACTIVATION OF MEDICARE BILLING PRIVILEGES DUE TO LACK OF BILLING

Volume 22.06 For several years we have cautioned health care providers that Medicare billing privileges could be deactivated if the provider did not submit any Medicare claims for twelve (12) consecutive months.  This deactivation is ...

HOSPICE ELECTION TO PARTICIPATE IN CMS PART D AND HOSPICE ELECTION PILOT PROGRAM

Volume 22.12 Hospices can sign-up to participate in the CMS Part D and Hospice Election Pilot Program through July 31, 2022.  The primary focus of the Pilot Program is the acceleration of communications and notifications between the Hospice, ...

HEALTH CARE FRAUD AND ABUSE CONTROL PROGRAM FY 2021 REPORT ISSUED

Volume 22.05 The Department of Health and Human Services and the Department of Justice have released the Health Care Fraud and Abuse Control Program Annual Report for Fiscal Year 2021.  During FY 2021, the federal government won or ...

CMS PROPOSES TO REDUCE NATIONAL STANDARDIZED 30-DAY PERIOD PAYMENT

Volume 22.03 The Centers for Medicare & Medicaid Services (“CMS”) has released the Proposed Rule, “Medicare Program; Calendar Year (CY) 2023 Home Health Prospective Payment Rate Update; Home Health Quality Reporting Requirements; Home ...

ASSESSING THE IMPACT OF CAP RECOMMENDATIONS BY MEDPAC

Volume 22.11 The Health Group, LLC constantly monitors recommendations of the Medicare Payment Advisory Commission (“MedPAC”) to Congress.  A significant recommendation of MedPAC relating to hospice reimbursement is to reduce the Medicare ...

Hospice Alert 22.10

IRS INCREASES ALLOWABLE MILEAGE REIMBURSEMENT Effective July 1, 2022, the standard mileage rate for business travel has been increased to 62.5 cents per mile, an increase of 4 cents from the current allowable reimbursement rate. This ...

Hospice Alert 22.09

 Volume 22.09 CLARITY IN CAP LIABILITY PROVISIONS OF PURCHASE AGREEMENTS  As more hospices exceed hospice aggregate payment limitations (“CAP”) and hospice acquisitions continue at a rapid pace, we are constantly becoming involved in disputes ...

HOSPICE CAP LIABILITY AND CLAIM DENIALS

Volume 22.08 As hospices become subjected to claims denials, whether such denials are the result of a UPIC or not, the hospice may be entitled to a refund of previously paid CAP liabilities.  We reported on this in 2021; however, The Health ...

COVID-19 PHE EXTENDED AGAIN

 Volume 22.04 The Biden administration on Wednesday extended the COVID-19 public health emergency that had been due to expire on April 16.  The 90-day extension, announced by the Department of Health and Human Services (HHS), will allow ...

CMS RELEASES PROPOSED 2023 PAYMENT UPDATE

 Volume 22.07 Yesterday, March 30, 2022, CMS issued the proposed rule that would update Medicare hospice payment rates and the aggregate payment limitation (“CAP”) effective October 1, 2022.  2022-07030.pdf (federalregister.gov). The ...

MedPAC REPORT RECOMMENDS REDUCTION IN HOME HEALTH PAYMENTS

Volume 22.02 The Medicare Payment Advisory Commission (“MedPAC”) made two recommendations to Congress in their recent Report.  These are as follows: “Our review of payment adequacy for Medicare home health services indicates that access ...

PRESIDENT SIGNS OMNIBUS SPENDING BILL

Volume 22.06 Last week President Biden signed into law a $1.5 trillion spending package, referred to as an “Omnibus Spending Bill”.  The legislation will fund the government through September 2022.  The Bill also provides significant ...

MEDICARE PAYMENT ADVISORY COMMISSION (“MedPAC”) ISSUES MARCH 2022 REPORT TO CONGRESS

Volume 22.05 MedPAC has released its March 2022 Report (“Report”) to Congress.  As expected, MedPAC has again recommended hospices not receive any payment update in 2023 and that the aggregate payment limitation (“CAP”) be wage adjusted and ...

REPORTING FOR USE OF PROVIDER RELIEF FUNDS

Volume 22.03 Many providers are confused regarding the required reporting for the use of Provider Relief Funds (“PRF”).  Reporting timelines are based on when the funds were received by the provider.  The following summarizes when funds must ...

Hospice Alert 22.04

 Volume 22.04 TECHNICAL CORRECTION Our last Hospice Alert (Volume 22.03) indicated that CMS revised the Hospice Cost & Data Report on September 25, 2022. The actual date of the revision was February 25, 2022, and is available ...

CMS MAKES MINOR CHANGES TO HOSPICE COST REPORT

 Volume 22.03 On September 25, 2022, CMS revised the Hospice Cost & Data Report to add a new non-reimbursable cost center to accumulate costs associated with suicide accomplished with aid of a physician in those states that allow ...

SELF-DETERMINED HOSPICE CAP OVERPAYMENTS

 Volume 22.02 According to MedPAC, almost 20% of all hospice providers are now exceeding the Medicare aggregate payment limitation (“CAP”).  Many hospices will have a CAP liability when they file their self-determined CAP liability report on ...

CHANGING HEALTHCARE COSTS AS A RESULT OF COVID-19 PHE AND THE AFTERMATH

Volume 22.02 Many healthcare providers, consultants to the healthcare industry, and other observers have been attempting to gain an understanding of the changes to the healthcare delivery systems and the changes in costs incurred by ...

CMS UPDATES THE MEDICARE PROGRAM INTEGRITY MANUAL TO ADDRESS NOA

Volume 22.01 Home health agencies no longer submit Requests for Anticipated Payment (“RAP”) at the start of a home health episode of care.  Effective January 1, 2022, agencies submit a Notice of Admission (“NOA”).  The Manual has been ...

MEDPAC AND HOSPICE CAP REDUCTION RECOMMENDATIONS

Volume 22.01 The Medicare Payment Advisory Commission (MedPAC) is an independent congressional agency established by the Balanced Budget Act of 1997 (P.L. 105-33) to advise the U.S. Congress on issues affecting the Medicare program. In ...

SUPREME COURT ALLOWS MANDATORY VACCINATIONS FOR HEALTH CARE PROVIDERS

Volume 22.01 On Thursday, the Supreme Court issued mixed rulings, allowing vaccine mandates for certain health care workers (Vote was 5-4), but blocking enforcement of a mandate for businesses with 100 or more employers (Vote was ...

READY FOR CAP REPORTING?

Volume 21.17 Medicare- certified hospices are required to self-report the calculated aggregate payment limitation (“CAP”) no earlier than three (3) months after, and no later than five (5) months after the end of the hospice CAP Year.  The ...

MEDICARE SEQUESTRATION DELAYED AND REDUCED IN LEGISLATION

Volume 21.15 The U.S. Senate is expected to pass legislation (already passed in the House of Representatives) that would: Implement an additional three (3) month suspension of the two percent (2%) Medicare sequestration payment ...

OIG REPORTS ON PALMETTO GBA, LLC CAP MANAGEMENT

Volume 21.16 The U.S. Department of Health & Human Services (“DHHS”) Office of Inspector General (“OIG”) issued a Report in July 2021 regarding the CAP management process of Palmetto GBA, LLC (“Palmetto”).  Palmetto was selected from the ...

CMS ISSUES EMERGENCY REGULATION REQUIRING COVID-19 VACCINATIONS

Volume 21.14 CMS is issuing an Interim Final Rule requiring most Medicare and Medicaid certified providers and suppliers to establish a policy ensuring that all eligible staff have received the first dose of a two-dose vaccine or a one-dose ...

HOME HEALTH PAYMENT RATES FINALIZED

Volume 21.07 CMS has finalized 2022 home health reimbursement rates.  Standard rates have increased by a net 2.6%, which is the result of an inflation update of 3.1% reduced by a .5% productivity adjustment. The base 30-day rate increased ...

PROVIDER RELIEF FUNDS – PHASE 4 APPLICATION SUBMISSION TIMING MODIFIED

 Volume 21.13 Over the weekend, the Health Resources and Services Administration (“HRSA”) modified certain details regarding the Phase 4 PRF application.  Information provided by HRSA now requires Phase 4 applicants to submit their Taxpayer ...

PHASE 4 OF PROVIDER RELIEF FUNDING REQUIRES AN IRS VALIDATION

 Volume 21.12 If you are going to apply for Phase 4 funding of Provider Relief Funds and have not yet applied for IRS validation, you should immediately submit required, but limited, information for IRS validation.  This process must be ...

PROVIDER RELIEF FUND (PHASE 4) UPDATE

Volume 21.11 Providers can apply for the new, Phase 4, Provider Relief Funds beginning September 29, 2021.  The application period will run through October 26, 2021.  The application will be made in the Provider Relief Application and ...

CAP HOSPICES NEED TO EXERCISE CAUTION IN REPORTING REVENUES TO SUPPORT THE USE OF PRF FUNDS

Volume 21.15 Many hospices incur CAP liabilities, which must be repaid to the Medicare program.  Information provided by HRSA regarding lost revenues does not specifically address CAP overpayments; however, HRSA Q&A includes the ...

USING YOUR BUDGET FOR CALCULATING LOST REVENUES FOR PRF REPORTING

Volume 21.10 Three methods are available to healthcare providers for determining lost revenues eligible to be applied as a qualified use of Provider Relief Funds.  These are: Option 1: Actual 2020 and 2021 revenues compared against 2019 ...

PHASE 4 COVID-19 PHE PROVIDER FUNDING

Volume 21.06 HHS Press Release: “The Biden-Harris Administration announced today that the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is making $25.5 billion in new ...

WILL ALL HEALTH CARE PROVIDERS BE REQUIRED TO MANDATE COVID VACCINATIONS?

Volume 21.05 It is reported that the U.S. Centers for Medicare & Medicaid Services (“CMS”) and the Centers for Disease Control and Prevention (“CDC”) are jointly involved in the development of changes in Conditions of Participation that ...

NAHC CANCELS 2021 HOME CARE AND HOSPICE CONFERENCE AND EXPO

Volume 21.14 Yesterday the National Association for Home Care & Hospice announced the cancellation of the upcoming 2021 Home Care and Hospice Conference and Expo, which was scheduled for October 3-5, 2021, in New Orleans. “This was a ...

AT HOME COVID-19 VACCINATION REIMBURSEMENT INCREASED

Volume 21.05 CMS has increased reimbursement to providers for in-home COVID-19 vaccinations as part of the efforts to provide opportunities for individuals who cannot leave their home, as well as increase the number of vaccinated persons.  ...

2021 HOSPICE FINANCIAL MANAGEMENT ACADEMY

 Volume 21.13 We are very excited to be sponsoring our Hospice Financial Management Academy live again.  The 2021 program will be held at the Paris Hotel and Casino in Las Vegas on September 13-14, 2021.  The response to this program has ...

2022 HOSPICE PAYMENT RULE RELEASED

 Volume 21.12 CMS has issued the final rule, “Medicare Program; FY 2022 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice and Home Health Quality Reporting Program Requirements”. This final ...

RULES FOR SINGLE AUDITS OF NONFEDERAL ENTITIES UPDATED TO ADDRESS PRF

Volume 21.04 The Department of Health and Human Services (“HHS”) has updated the rules relating to the reporting of Provider Relief Funds (“PRF”) use by nonfederal entities as part of the single audit requirements. Recipients that expend ...

RULES FOR SINGLE AUDITS OF NONFEDERAL ENTITIES UPDATED TO ADDRESS PRF

Volume 21.09 The Department of Health and Human Services (“HHS”) has updated the rules relating to the reporting of Provider Relief Funds (“PRF”) use by nonfederal entities as part of the single audit requirements. Recipients that expend ...

HOSPICE MERGERS AND ACQUISITIONS CONTINUE AT RAPID PACE

Volume 21.11 Hospices continue to lead the healthcare sector in investor interest and valuation even during the COVID-19 PHE.  The price of hospices continues to rise due to the continually increasing demand and return opportunities expected ...

HOSPICE FINANCIAL MANAGEMENT ACADEMY UPDATE (ROOM BLOCK AND REGISTRATION)

Volume 21.10 The early response to our Hospice Financial Management Academy, scheduled for September 13-14, 2021, has been overwhelming.  We have ten (10) remaining spots available for the program (we limit attendance to maximize the benefit ...

COULD YOUR HOSPICE OVERPAY A CAP LIABILITY?

Volume 21.09 Recently, we have identified another hospice that has overpaid its CAP liability.  This happens when a hospice has claims denied and is also subject to CAP overpayments. When a claim is retroactively denied for a completed ...