(304) 241-1261 contact@healthgroup.com

News Alerts

VBID AND HOSPICE CAP CALCULATIONS

Volume 24.06 Hospices that have and are currently participating in the VBID Model Hospice Benefit often inquire as to the impact on their aggregate payment limitation (“CAP”) caused by patients served through the VBID contract.  VBID ...

NAHC/HHFMA REQUESTS ASSISTANCE IN ADDRESSING MEDICARE ADVANTAGE AND HOME HEALTH AGENCY RELATIONSHIPS

 Volume 24.02 The National Association for Home Care and Hospice (“NAHC”) is initiating a landmark survey focusing on the operational and financial aspects of the relationship between home health agencies and Medicare Advantage (“MA”) plans.  ...

HOSPICES MUST REPORT THEIR MEDICAL DIRECTOR TO MEDICARE NOW

Volume 24.05 The 2024 Home Health Prospective Payment System (“HH PPS”) Rate Update final rule included a provision clarifying that the definition of a Managing Employee in 42 CFR §424.502 includes the administrator and medical director of a ...

NATIONAL HOSPICE AUDIT 2023 SURVEY REPORT RELEASED

Volume 24.04 LeadingAge, the National Association for Home Care & Hospice (“NAHC”), the National Hospice and Palliative Care Organization (“NHPCO”), and the National Partnership for Healthcare and Hospice Innovation (“NPHI”) have released ...

HOSPICE VBID COMES TO AN END

 Volume 24.03 In a stunning development, yesterday the U.S. Centers for Medicare & Medicaid Services (“CMS”) announced that the hospice component of the value-based insurance design model (“VBID”) will end on December 31, 2024. The ...

DEPARTMENT OF LABOR ISSUES FINAL RULE REGARDING EMPLOYEE OR INDEPENDENT CONTRACTOR STATUS

 Volume 24.01 On January 10, 2024, the Wage and Hour Division of the Department of Labor (“DOL”) issued a Final Rule (“Rule”) regarding “Employee or Independent Contractor Classification Under the Fair Labor Standards Act.”  The Rule is ...

HOSPICE SELF-DETERMINED CAP LIABILITY SUBMISSIONS

Volume 24.02 As a reminder, hospices must submit their self-determined CAP liability reports on or before February 29, 2024, for the 2023 CAP Year, which ended on September 30, 2023.  If the report indicates a liability due to the Medicare ...

MINOR HOSPICE COST REPORT CHANGES

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 ...

Medicare Payment Advisory Commission Addresses Hospice Program and Payments

Volume 23.23 At the December meeting of the Medicare Payment Advisory Commission (“MedPAC”), the only recommendation presented was to eliminate the update to the 2024 Medicare hospice payment rates.  A formal vote by MedPAC on the ...

MEDPAC PREPARES TO RECOMMEND SUBSTANTIAL REDUCTION TO HOME HEALTH PAYMENTS

 Volume 23.09 At the recent meeting of the Medicare Payment Advisory Commission (“MedPAC”), the staff presented to the commissioners the following: Medicare margins have declined, Medicare home health expenditures have declined, ...

CMS RELEASES MEDICARE ENROLLMENT APPLICATION FEE FOR 2024

 Volume 23.08 CMS has announced a $709 calendar year application fee for providers that are: Initially enrolling in the Medicare program, Medicaid program, or the Children’s Health Insurance Program (“CHIP”), Revalidating their ...

CMS MOVES ON ADDITIONAL OWNERSHIP DISCLOSURES FOR NURSING FACILITIES

Volume 23.07 On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) placed on display at the Federal Register a Final Rule that will implement portions of section 6101 of the Affordable Care Act, requiring the disclosure ...

MEDICARE ENROLLMENT PROVISIONS INCLUDED IN PHYSICIAN FEE RULE FINALIZED

Volume 23.06 The Centers for Medicare and Medicaid Services (“CMS”) has finalized the CY 2024 Medicare Physician Fee Schedule rule.  Many enrollment-related provisions were included in the proposed rule.  The Health Group, LLC discussed the ...

Calendar Year (CY) 2024 Home Health Prospective Payment System Final Rule

On November 1, 2023, the Centers for Medicare & Medicaid Services (CMS) issued the calendar year (CY) 2024 Home Health Prospective Payment System (HH PPS) Rate Update final rule, which updates Medicare payment policies and rates for Home ...

CMS FINALIZES HOME HEALTH RULES – HOSPICES SIGNIFICANTLY IMPACTED

Volume 23.22 Yesterday, CMS finalized the Home Health Prospective Payment System Rate Update which includes many provisions impacting hospices.  The following provider enrollment regulations were finalized: § 424.502 Definitions. ...

USE OF VOLUNTEERS

Volume 23.21 CMS waived the requirement for hospices to use volunteers (42 CFR §418.78(e)) during the Public Health Emergency (“PHE”); however, the requirement is again effective January 1, 2024.  Many hospices had difficulty complying with ...

IRS ANNOUNCES WITHDRAWAL PROCESS FOR EMPLOYEE RETENTION CREDIT CLAIMS

 Volume 23.05 Many healthcare providers, for-profit and tax-exempt, submitted claims to secure the Employee Retention Credit based on lost revenues; however, many submitted claims based on other criteria related to the issuance of government ...

CONSIDERING PIP REIMBURSEMENT FOR HOSPICES

Volume 23.20 Most healthcare providers are not eligible for Periodic Interim Payment (“PIP”) reimbursement; however, hospices are eligible.  The beginning of a hospice’s fiscal year is the perfect time to request PIP reimbursement in lieu of ...

FOUR PLANS DROP OUT OF MA VBID FOR 2024; TWO NEW PLANS WILL PARTICIPATE

Volume 23.19 CMS has posted those plans that will be participating in the Medicare Advantage Value-Based Insurance Design Model in 2024, including those participating in the Hospice Benefit Component. There will be less Hospice Benefit ...

MEDICAID HOSPICE PAYMENT RATES UPDATED

Volume 23.18 The U.S. Centers for Medicare & Medicaid Services has updated Medicare hospice payment rates effective October 1, 2023.  Although not consistent with Medicare payment rates, the rates are calculated based on established ...

PROCESSING TIME FOR MEDICARE ENROLLMENT APPLICATIONS – AN INCREASING PROBLEM FOR PROVIDERS

Volume 23.04 Many providers are dealing with significant delays in processing Medicare enrollment updates and new enrollment applications.  It is not unusual to see approvals of CMS 855 filings taking four months to a year.  Change of ...

TARGETING HOSPICES BY CMS HEIGHTENS

Volume 23.17 Yesterday the Centers for Medicare and Medicaid Services (“CMS”) reported that nearly 400 hospices are being considered for potential administrative action.  This is the result of site visits to numerous hospices.  The site ...

JUDGE ORDERS STATE TO PROVIDE PRIVATE DUTY NURSING CARE

Volume 23.07 The following was reprinted with permission of Elizabeth E. Hogue, Esq. On July 14, 2023, a Judge issued an opinion and order, in which he said that the State of Florida must provide services, including private duty nursing ...

FY 2024 HOSPICE PAYMENTS FINALIZED; RATES INCREASE 3.1%

Volume 23.16 On July 28, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a final rule (CMS-1787-F) that updates Medicare hospice payments and the aggregate CAP amount for fiscal year (FY) 2024 in accordance with existing ...

NUMEROUS PROVIDER ENROLLMENT CHANGES INCLUDED IN THE MEDICARE PHYSICIAN FEE SCHEDULE PROPOSED RULE

Volume 23.03 CMS’s increasing focus on provider integrity continues as they have proposed numerous Medicare enrollment changes impacting healthcare providers of all types.  The proposed rule includes, but is not limited to, the ...

CMS MODIFIES CALCULATION OF 2022 CAP YEAR LIABILITIES

Volume 23.15 ]On July 20, 2023, CMS instructed the Medicare Administrative Contractors (“MACs”) to modify the calculation of hospice CAP liabilities for the 2022 CAP Year.  The modified calculation will be made to appropriately apply ...

CMS PLACES NEW HOSPICES IN CALIFORNIA, TEXAS, ARIZONA, AND NEVADA IN ENHANCED OVERSIGHT PROGRAM

Volume 23.14 Effective today, July 13, 2023, CMS has placed new hospices, defined below, in a provisional period of enhanced oversight.  A new hospice is defined as: A new enrollee in the Medicare program on or after July 13, 2023, A ...

NAHC ANNOUNCES LAWSUIT AGAINST CMS REGARDING HOME HEALTH PAYMENT RATES

Volume 23.06 On July 6, 2023, The National Association for Home Care and Hospice (“NAHC”) announced that it has filed a lawsuit against the Centers for Medicare and Medicaid Services (“CMS”) which challenges the manner that CMS has reduced ...

HOSPICE INTEGRITY MEASURES PROPOSED IN HOME HEALTH RULE INCLUDING APPLICATION OF 36-MONTH RULE

Volume 23.13 We have been continuously reporting on the numerous hospice provider integrity measures being considered. CMS is now proposing as part of the Calendar Year (CY) 2024 Home Health (HH) Prospective Payment System Rate Update ...

HIGH-RISK MEDICARE GENERAL INPATIENT SERVICES TARGETED BY CMS

Volume 23.12 In June 2023, the U.S. Department of Health and Human Services, Office of Inspector General (“OIG”) has added the “Audit of Selected, High-Risk Medicare Hospice General Inpatient Services” to the OIG Work Plan. According to ...

MEDICARE ADMINISTRATIVE CONTRACTOR’S MANAGEMENT OF HOSPICE CAP

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 ...

MANY HEALTHCARE PROVIDERS AT RISK FOR IRS RECOVERY OF ERC CREDITS

Volume 23.01 On March 7, 2023, the IRS issued a warning to Employee Retention Credit claims.  False claims generate compliance risk for people and businesses claiming improper credits.  According to the warning, “The IRS and tax ...

2024 PROPOSED HOSPICE PAYMENT UPDATE WILL SIGNIFICANTLY IMPACT HOSPICE PROVIDERS

Volume 23.10 Under the proposed hospice payment rule, payments to hospices for the year beginning October 1, 2023, will increase by only 2.8%.  This increase in base rates, adjusted by geography, is not close to the overall increase in the ...

HOSPICE SPECIAL FOCUS PROGRAM PROPOSAL EXPECTED THIS SUMMER

Volume 23.09 The Consolidated Appropriations Act (CAA) of 2021 authorized the Secretary of Health & Human Services to create a Special Focus Program (SFP) which aims to address issues that place hospice beneficiaries at risk for poor ...

HOSPICE PROGRAM INTEGRITY – FIRST AND FOREMOST IN THE MIND OF CMS

Volume 23.08 The 2024 Proposed Hospice Rule is only one indicator of the increased focus by CMS and federal legislators on hospice program integrity. CMS, in the 2024 Proposed Rule, has reported significant information regarding hospice ...

HOSPICE OWNERSHIP INFORMATION AVAILABLE

Volume 23.07 The U.S. Department of Health and Human Services (“DHHS”) is releasing information on the ownership of over 6,000 hospices and 11,0000 home health agencies certified to participate in the Medicare program on the Centers for ...

CMS RELEASES PROPOSED FY2024 HOSPICE RULE

Volume 23.06 On Friday, March 31, 2023, the Centers for Medicare & Medicaid Services issued the proposed rule, Medicare Program; FY 2024 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice ...

MEDPAC RECOMMENDS SUBSTANTIAL REDUCTION TO HOME HEALTH PAYMENTS

Volume 23.04 MedPAC’s March 2023 Report to Congress included the following recommendation: “Our review of payment adequacy for Medicare home health services indicates that access is more than adequate in most areas and that Medicare ...

MEDPAC AGAIN RECOMMENDS CHANGES TO HOSPICE CAP

Volume 23.05 According to the March Report to Congress, “Based on the generally positive indicators of payment adequacy and strong margins, the Commission concludes that a reduction to aggregate payments is warranted. However, in this ...

HOSPICE SELF-DETERMINED CAP LIABILITIES – WHEN IS PAYMENT REQUIRED?

Volume 23.04 There is substantial confusion regarding when overpayments determined by self-determined CAP liability filings are required to be paid.  The regulations are clear that any CAP liability determined by self-filing is due at the ...

NAHC and NHPCO Exploring Collaboration Opportunities

 Volume 23.03 The Health Group, LLC has been a member of both the National Association for Home Care & Hospice and the National Hospice and Palliative Care Organization for many years.  We are pleased to reprint the public news release ...

HOSPICE EDUCATIONAL OPPORTUNITIES UPCOMING

Volume 23.03 It is not too early to plan for and schedule your educational plan for 2023.  As the COVID-19 Public Health Emergency comes to an end, many regulatory changes are already occurring and many more are forthcoming.  Additionally, ...

HOME HEALTH AGENCIES – END OF THE COVID-19 PHE

 Volume 23.02 CMS used emergency waiver authorities and other regulatory processes to better enable providers to rapidly respond to individuals impacted by COVID-19.  Currently, CMS is: Assessing the need for continuing certain blanket ...

CMS RELEASES REVISIONS TO THE HOSPICE SURVEY PROCESS AND SURVEYOR TRAINING

Volume 23.02 Revisions to Appendix M of the CMS State Operations Manual have been released.  The revisions are effective immediately; however, state survey directors have thirty (30) days to communicate the changes.  State surveyors and ...

FISCAL YEAR 2023 APPROPRIATIONS BILL

 Volume 23.01 The Fiscal Year 2023 Appropriations Bill (“Omnibus Budget”) recently passed includes the following of immediate interest to home health providers: Sequestration – The legislation extends Medicare sequestration into 2032 and ...

FISCAL YEAR 2023 APPROPRIATIONS BILL

Volume 23.01 The Fiscal Year 2023 Appropriations Bill (“Omnibus Budget”) recently passed includes the following of immediate interest to hospice providers: Sequestration – The legislation extends Medicare sequestration into 2032 and sets ...

OPPOSE CAP REDUCTIONS IN ANY CONGRESSIONAL ACTION

Volume 22.17 All hospice providers need to be vocal regarding any efforts that Congress may take to reduce the Medicare CAP as part of any end-of-year legislative package.  The National Association for Home Care and Hospice (“NAHC”) has ...

CMS UPDATES MEDICARE ENROLLMENT INSTRUCTIONS

 Volume 22.12 Effective December 5, 2022, certain modifications have been made to Chapter 10 of the Medicare Program Integrity Manual dealing primarily with “Ownership Disclosures”, “Electronic Funds Transfers”, and “Special Payment ...

OIG REPORTS ON PROVIDER RELIEF FUND REQUIREMENT IMPROVEMENTS

Volume 22.11 In September 2022, the Department of Health and Human Services Office of Inspector General (“OIG”) released a report entitled “HHS’s and HRSA’s Controls Related to Selected Provider Relief Fund Program Requirements Could Be ...

DON’T FORGET PRF PHASE 4 REPORTING IS UPCOMING

Volume 22.16 Many providers received Phase 4 funding (payment received between July 1, 2021, and December 31, 2021) of more than $10,000.  These funds are used for lost revenues and qualifying COVID-19 expenses incurred between January 1, ...