The National Association for Home Care and Hospice (NAHC) has put together a list of issues related to the new CMS requirements for hospices to self-calculate and report their aggregate cap status to their assigned Medicare Administrative Contractor (MAC) within five months following the close of the cap year. During this time frame, hospices are also required to pay back or make payment arrangements for any liability. There is some confusion among hospice providers about the applicability of the requirement and how to meet it on a timely basis. NAHC has put together an article that provides answers to frequently-asked questions related to the hospice cap reporting requirement and supplied information on how providers can meet the requirement. Click here to read NAHC’s article.
In 2012, CMS began development and release of Program for Evaluating Payment Patterns (PEPPER) reports for Medicare-certified hospices through its PEPPER contractor, TMF Health Quality Institute. As part of the PEPPER process, certain “target areas” within the Medicare hospice benefit that could be at risk for improper payment are identified, and the data related to target areas is analyzed. The PEPPER reports “supply an individual hospice’s data over three years’ time and also provide, for comparison, the same data for hospices, nationally, within the same Medicare Administrative Contractor (MAC) jurisdiction, and within the same state as the subject hospice.” The data allows a hospice to assess its performance and risks in the target areas. Starting in April, PEPPER reports are becoming available by way of an electronic PEPPER Resources Portal. TMF Health Quality Institute is expected to release the latest hospice PEPPER in mid-April. The PEPPER target areas for hospice have also been expanded.
Click here to see them and for more information from NAHC.
Click here to see the fourth edition of the PEPPER Hospice User’s Guide.
As part of the FY 2015 final hospice payment rule, all hospices must self-calculate their aggregate cap and submit them to their Medicare Administrative Contractor (MAC) within five months of the close of the cap year or risk suspension of payment. A final determination of a hospice’s aggregate cap liability will be calculated by the hospice’s MAC at a later time. On Monday, CMS released a spreadsheet and instructions for use by hospices for self-calculating their 2014 aggregate cap. The release of the spreadsheet had previously been delayed as CMS and HHS resolved the most appropriate method for addressing the 2% sequester as part of the overall cap determination. CMS is not requiring that a hospice take the sequester into consideration as part of its initial cap self-calculation. Instead, the hospice’s MAC will incorporate the sequester as part of the final cap liability determination at a later date.
Hospices should anticipate that their MACs will be circulating the pro-forma spreadsheet and instructions for self-calculation of the aggregate cap in the very near future – along with details as to where hospices should send their cap spreadsheets and any overpayment. In order to complete the spreadsheet, hospices should secure information from the Provider Statistical & Reimbursement Report (P S & R) system. However, due to CMS transitioning the P S & R application from the IACS system to the EIDM system, providers have been unable to register to secure access to the P S & R.
Palmetto GBA has issues letters to its hospice providers with the data that will be needed to complete the cap self-calculation. Palmetto has also posted additional information regarding the cap self calculation and submission. Click here to see it.
It is NAHC’s understanding that while neither NGS nor CGS plan to issue letters with the P S & R data needed to self-calculate the cap on a jurisdiction-wide scale, both will still consider requests from individual hospice providers for the necessary P S & R information on a case-by-case basis. NGS and CGS are expected to post additional information on their websites in the near future.
CGS hospice providers who do not have access to their P S & R reports may submit a request to CGS for the cap data by contacting the CGS General Provider Contact Center at 877-299-4500 (select Option 1) and a referral will be made to the CGS Provider Audit department.
NGS providers who do not have access to their P S & R reports may submit an email requesting the information to PS&R@anthem.com.
Click here for information from NAHC, including CMS’ instructions for self-calculation of the aggregate cap.
The CY 2015 Medicare Physician Fee Schedule (MPFS) final rule was published in the Federal Register on November 13, 2014. Medicare Administrative Contractors will hold claims containing 2015 services paid under the MPFS for the first 14 calendar days of January 2015 in an effort to implement corrections to technical errors discovered after the publication of the MPFS rule. Please note, this hold will have a minimal impact on provider cash flow as, under current law, clean electronic claims are not paid sooner than 14 days (29 days for paper claims) after the date of receipt. MPFS claims for services provided on or before Wednesday, December 31, 2014 are unaffected by the 2015 claims hold and will be processed and paid under the normal procedures and time frames.
Click here to see the Final Rule.
Click here to read more.