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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 2021 CAP Year runs from October 1, 2020, through September 30, 2021.  The filing deadline is February 28, 2022.

Data used in the determination of the CAP and payments relating to services rendered during the 2021 CAP Year are secured through the Provider Statistical & Reimbursement (“PS&R”) System.

Each of the Medicare Administrative Contractors (“MAC”) provides information on the filing.  The respective MAC may make additional updates.

Palmetto GBA

Hospices should secure beneficiary counts and payments for the 2021 CAP Year as soon as possible from the PS&R System after January 1, 2022, to minimize any liability reported on or before February 28, 2022.

If the Hospice has a CAP liability, it may be possible to secure an Extended Repayment Schedule (“ERS”).  Interest rates are high and substantial information is required if the Hospice requests an ERS more than eleven (11) months.  Determining a CAP liability, as soon as possible allows the Hospice to accumulate the required information to support an ERS request.

Liability Assessments

The Hospice may want to make estimates of any ultimate CAP liability for the 2021 CAP Year at the same time as securing PS&R data for CAP reporting.  CAP liability assessments provide information supporting financial reporting and cash flow planning.


December 31, 2021 is the last day of the calendar year 2021 participation requirement for the Consumer Assessment of Healthcare Providers and Systems (“CAHPS”) Hospice Survey and the Hospice Information Set (“HIS”).  Failure to meet participation requirements will cause a two percent (2%) reduction to FY 2023 payments.


The 2022 Leadership and Advocacy Conference, sponsored by the National Hospice and Palliative Care Organization (“NHPCO”), is scheduled for March 7-9, 2022, at the Gaylord National Resort & Convention Center.  The program is scheduled to be a live, in-person event.  Registrations are being accepted.


All of us at The Health Group, LLC wish you, your family, and your friends a Happy New Year!