News Alerts
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, ...
HOME HEALTH PAYMENTS RULE RELEASED
Volume 22.06
On October 31, 2022, the Centers for Medicare & Medicaid Services ("CMS") issued the calendar year ("CY") 2023 Home Health Prospective Payment System ("HH PPS") Rate Update final rule, which updates Medicare payment policies ...
MAJOR REVISIONS MADE TO HOME OFFICE COST REPORT
Volume 22.10
The U.S. Centers for Medicare & Medicaid Services has released Home Office Cost Statement, Form CMS-287-22 (“Home Office Cost Report”). R1P248i | CMS
The new Home Office Cost Report (CMS-287-22) is effective for cost ...
EMPLOYEE OR INDEPENDENT CONTRACTOR
Volume 22.05
EMPLOYEE OR INDEPENDENT CONTRACTOR
The Department of Labor has released a “Notice of Proposed Rulemaking” (“Notice”) today, which proposes to modify Wage and Hour Division regulations relating to the determination of whether ...
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 ...
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