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 patients and the days the patient is provided hospice services paid by the Medicare Advantage Organization (“MAO”) are not considered in the hospice CAP calculation of the serving hospice or any other hospice that served the patient through traditional Medicare.
FAQs released by CMS include the following:
“Claims paid by MAOs under the VBID Hospice Benefit Component are not reflected on PS&R reports. Accordingly, days of hospice care covered by a participating MAO are not included in the hospice inpatient and aggregate CAP calculations.” More information is available here.
This is also included on Medicare Administrative Contractor (“MAC”) websites. Palmetto GBA has released the following:
“All billing related to care provided to an enrollee who have coverage through a plan participating in the Hospice Benefit Component shall not be included in calculating a hospice’s progress toward the aggregate and inpatient CAP.” More information is available here.
AN INCREASING NUMBER OF HOSPICES WILL BE ENTITLED TO CAP LIABILITY REFUNDS
As more hospices become subject to claims denials and Medicare program repayments because of these denials, many hospices become eligible for refunds of CAP liabilities paid to the Medicare program. Many of the claims denied are associated with patients who had longer lengths of stay during the terminal episode of care. Accordingly, the denial of these claims generally decreases any historical CAP liability.
The Medicare Administrative Contractor (“MAC”) recalculates the hospice CAP liability based on their recalculation schedule but only for years they determine appropriate for recalculation.
The increase in claim reviews has resulted in more hospices being eligible for CAP liability refunds. We have identified several hospices entitled to refunds for years which would not have been recalculated by the respective MAC. In these situations, the hospice must request a recalculation. We recommend that in these situations the hospice not only requests a recalculation but also provide the calculation supporting their refund request.
The MAC will not issue any refund of recovered CAP liabilities until the payment related to the claim denials has been recovered.
VISIT WITH US TO DISCUSS ANY CAP ISSUES YOU MAY HAVE
The Health Group, LLC will be attending and exhibiting at the 2024 NAHC Financial Management Conference in Las Vegas on July 21-23, 2024. We encourage you to visit us at Booth #217 to discuss any hospice CAP, cost reporting, Medicare enrollment, tax, or accounting and financial reporting issues. Do not hesitate to contact us at contact@healthgroup.com to let us know you will be attending or to arrange a meeting time during the conference.
2024 FINANCIAL MANAGEMENT AND ADMINISTRATIVE CONFERENCE
We are in the final stages of finalizing our plans for The Health Group 2024 Financial and Administrative Conference. Details will be made available very soon. Contact us to make certain you receive the conference information as soon as possible. Attendance is always limited to better ensure the quality of the program.