Historically, the hospice cap year has begun November 1 and ended October 31. However, when the Centers for Medicare & Medicaid Services (CMS) issued the 2016 final rule CMS-1629-F, FY 2016 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements on August 6, 2015, the hospice cap accounting year was changed to align with the federal fiscal year. In the 2016 final rule, the fiscal year (FY) 2017 hospice cap year was determined to be the transition year. Therefore, the FY 2017 hospice cap period will be November 1, 2016, to September 30, 2017, and only will cover a period of 11 months with an aggregate cap amount of $28,404.99 per beneficiary. For FY 2018 and beyond, hospice cap periods will once again cover a full 12-month period with a cap period of October 1 through September 30.
With the change in the hospice cap year-end date, the deadline for submitting the hospice self-determined aggregate payment cap reports to providers’ respective Medicare Administrative Contractors (MAC) also has changed. Hospice providers are required to file a self-determined cap report between three and five months after the hospice cap year ends. Therefore, the earliest hospice providers can file is December 31, 2017, and the latest date to file is February 28, 2018. Failing to file the report on time can result in suspension of Medicare payments to the provider.
Also with the change, the CMS provided guidance in the 2018 final rule regarding the time frames to be used to count beneficiaries and payments for the aggregate cap in the 2017 and 2018 cap years. The table below lists those time frames.
The CMS requires that the self-determined cap report cover a full cap year. Therefore, if a hospice provider became Medicare-certified after November 1, 2016, it won’t need to file a hospice cap report for FY 2017, as its first submission will be for FY 2018 and should include a weighted average computation for months in each cap period since the provider’s inception.
Further instructions for completing and submitting the hospice self-determined aggregate payment cap reports can be found on each of the regional home health and hospice MAC websites:
National Government Services
If you have questions or would like assistance preparing your self-determined payment cap reports, contact Jessica or your trusted BKD advisor.