Volume 25.06
The Health Group, LLC is pleased to announce that registrations are now being accepted for the 2025 Hospice Financial Administration Conference scheduled for October 16-17, 2025. The conference will be held at the Hilton Orlando Buena Vista Lake.
In response to feedback from prior program attendees, several topics have been expanded and concurrent programming is available to facilitate meeting the needs of the attendees, whether administrative management, accounting management and personnel, or those more interested in clinical management or program integrity issues.
The program also offers an expanded Hospice CAP session and cost report session in response to requests by previous attendees. As always, space is limited at our programs to provide for more interactive discussions intended to meet your educational needs.
The program will be updated for any new developments through the date of the program; however, the agenda provides for program integrity issues, the continued expansion of claims review and denial efforts that come in a variety of forms, potential Medicaid payment reforms which could impact hospice providers, potential inclusion of hospice in Medicare Advantage, and expanded service efforts by hospice providers. Government efforts to reduce costs by identifying fraud and abuse in payments to healthcare providers, including hospices, has continued, and has been expanded under the current administration.
The program agenda, hotel reservation link, and registration information are available here. Early registration discounts are available. We look forward to seeing you in Orlando.
SPOTLIGHT ON PPEO
Under Section 1866(j)(3)(A) of the Social Security Act of 1935, the US Secretary of the Department of Health and Human Services (“HHS”) has the authority to establish procedures for a Provisional Period of Enhanced Oversight (“PPEO”) over Medicare providers and suppliers. A PPEO can last between 30 days and one year and allows CMS to take actions such as prepayment medical review and payment caps. CMS has utilized this authority to place new hospices in Arizona, California, Nevada, and Texas on a PPEO. The HHS Secretary may establish a PPEO by program instruction or other sub regulatory guidance.
A new provider or supplier for purposes of a PPEO is defined as a newly enrolling Medicare provider or supplier, a certified provider or certified supplier undergoing a change of ownership consistent with the principles of 42 CFR 489.18, or a provider or supplier (including a home health agency or hospice) undergoing a 100% change of ownership via a change of information request under 42 CFR § 424.516. This covers any 100% change of ownership regardless of the form. CMS has stated that the effective date of a PPEO is the date the new provider submits its first claim as opposed to date of enrollment.
In the Final Rule, CMS included providers that are reactivating their Medicare billing privileges under 42 CFR 424.540(b) in the definition of a “new provider or supplier” as it relates to a PPEO authority. CMS stated in commentary to the Final Rule that reactivation is effectively establishing a new provider or supplier for purposes of Medicare.
While some hospices have successfully navigated a PPEO, we are now seeing hospices that are experiencing significant denials and revocations of billing privileges because of PPEO. Hospices should be keenly aware of the potential of being subjected to PPEO and may want to secure the services of outside consultants in preparation of this potential.
SEE YOU IN CHICAGO AT THE ALLIANCE FINANCIAL SUMMIT
The Health Group, LLC and affiliate, Gray Griffith & Mays – Morgantown, PLLC will be exhibiting at the upcoming Alliance Financial Summit in Chicago on July 27-29, 2025. We hope that, if you are attending, you will stop by and visit us at Booth 617. We are pleased to discuss your cost reporting, Hospice CAP management, Medicare enrollment, financial reporting, merger/acquisition, or tax compliance needs. Contact us if you want to schedule a specific time to talk.
Registration is available here.