On April 30, 2015, CMS released its FY 2015 Hospice Wage Index, including long anticipated payment reform and some changes to the hospice cap calculation. Comments are due by June 29. Here is an initial summary and analysis.
Hospice Law Blog
News and Updates on Hospice Reimbursement Issues
The Hospice Law Blog, published by Sheppard, Mullin, Richter & Hampton LLP, focuses on legal and regulatory issues affecting hospice care providers. It covers topics such as hospice licensure and moratoriums, Medicare payment policies including hospice cap regulations and repayment demands, telehealth adaptations for hospice recertification, and the impact of federal legislation like the CARES Act on hospice operations. The blog also addresses challenges faced by hospices during public health emergencies, including COVID-19, discussing regulatory waivers, telehealth implementation, and patient care considerations. It provides updates on government oversight, compliance requirements, and policy changes relevant to hospice providers and stakeholders.
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ALJ Now Dismissing Hospice Appeals For Allegedly Insufficient Service On Beneficiary
In the last few years, we have seen a growing and alarming trend of administrative law judges (“ALJ”) dismissing appeals solely based on purported lack of service to the hospice patient (the Medicare beneficiary). A search of recent decisions shows…
Sequestration Adjustments To Hospice Cap – See Examples
As quietly promised, Medicare Administrative Contractors (NGS, Palmetto) have begun issuing FY 2013 cap demands with sequestration (money never paid) included as a part of revenue, thus overstating the demands. The demand letters themselves do not call out the sequestration…
MACs Issue FY 2013 Hospice Cap Demands With Sequestration; Group Appeal Now Open
Hospices in the Palmetto regions have begun receiving FY 2013 cap demands that include sequestration (money never paid to the hospice) as a part of a cap revenue under CMS’ new policy.
Other MACs are expected to follow shortly.…
Hospices To Self-Report Cap Without Sequestration; MACs To Capture Sequestration Later
This week, the Medicare Administrative Contractors issued instructions for hospices to self-report FY 2014 hospice cap (reports due this month, March 31, 2015). These instructions include a spreadsheet substantially similar to what we offered earlier this year. Hospices that fail to…
Attending Physician Documentation Changes Increase Audit Risk
On October 1, 2014, CMS revised its attending physician requirements, setting another potential trap for the unwary. 42 C.F.R. 418.24 [Election of Hospice].
While statute and regulation have long required both the attending physician and hospice medical director to certify…
CMS Plans To Add Sequestration Dollars To Hospice Cap
This week at an Open Door Forum, CMS finally disclosed a long-rumored plan to overstate hospice cap liability for hospices, and thereby grab more overpayments, by adding sequestered revenue to hospice revenue. For hospices, if not challenged, this will mean…
2014 Cap Year Mandatory Hospice Cap Calculation – Be Ready
With the 2014 cap year just concluded, it’s time to think about the new cap calculation requirements.
Over the summer, CMS finalized its revisions to the hospice cap rule, requiring hospices beginning with cap year 2014 (just completed) to calculate…
New CMS Hospice Item Set Reporting Invades Privacy Rights
For admissions on and after July 1, 2014, CMS will require hospices to file detailed reports (link) for every patient served including every type of personal information (social security number, full name, Medicare HICN, DNR detail, and details…
CMS Proposes: Calculate Your Own Cap (CYOC)
In its May 2014 publication of the 2015 Hospice Wage Index update, CMS proposes that hospices be required to calculate, report and pay their own hospice cap liability, with reports to be due five months past fiscal year end (i.e.,…