Self-Determined Hospice Aggregate Payment Cap Report Due March 31
On March 3, 2015, the Centers for Medicare & Medicaid Services (CMS) provided final guidance related to hospices’ required submission of self-determined hospice aggregate payment cap reports to their regional home health and hospice Medicare Administrative Contractor (MAC). This new requirement begins with the most recent cap year, ended October 31, 2014, and the report must be filed with your MAC within five months of the end of the cap year, or March 31, 2015, for the most recent cap year.
The new hospice cap filing requirement applies to all hospice provider types, including freestanding and provider-based hospices. Hospice providers failing to submit their self-determined aggregate payment cap report by the March 31 deadline will face withholding on their Medicare hospice payments.
With the new guidance, CMS provides a form to help hospices assess their potential payment cap liability and identify information they want included in the submission. This Provider Self-Determined Aggregate Cap Limitation form is available to calculate and submit your filing. The MACs have indicated hospice providers don’t need to resubmit on this form if they previously filed their self-determined aggregate cap calculations using a comparable format.
CMS also provided Instructions for Completing the Provider Self-Determined Aggregate Cap Limitation for the payment cap calculations and reporting.
In its final guidance, CMS answered one of the significant questions: Should the hospice payments that are compared to the computed cap be pre-sequestration payment amounts or payments after sequestration reductions? CMS says hospice providers should submit their self-determined payment cap using “net” payments—payments after sequestration reductions. MACs will make the adjustment for sequestration at the time of the final cap determination. If a hospice is over the cap, the MAC will compute an additional liability for sequestration.
The CMS transition from Individuals Authorized Access to the CMS Computer Services (IACS) to Enterprise Identity Management (EIDM) has caused some providers to experience issues accessing the required Provider Statistical & Reimbursement Report (PS&R) reports for computing the hospice cap. EIDM is not yet up and running as expected, but providers still can run their PS&R reports from IACS. The IACS systems won’t allow profile changes or addition of providers, so if you don’t currently have your hospice provider number(s) up in IACS, contact your MAC for assistance obtaining the necessary PS&R reports for the self-determined payment cap.
Each of the regional home health and hospice MACs, including CGS, NGS and Palmetto GBA, provided cap reporting contact information and additional instructions on where to file the self-determined payment cap as well as where to send payment for cap liabilities. Extended repayment plans are an option for cap liabilities but must be requested in advance or at the time of the provider’s cap filing.
If you have questions or would like assistance preparing your self-determined payment cap reports, contact your BKD advisor.