Hospice Law

Hospice Notice of Election / Direct Data Entry Perils

In October 2014, Medicare adopted new policy (not a statute, not a regulation) requiring hospices to submit any notice of election within five days of admission. Medicare backed this policy (lacking any force of law) with substantial apparent teeth: “In…


Hospice Payment Changes Take Effect

With the advent of the 2016 (Happy New Year!), hospices now face the revised hospice payment system. Specifically, Medicare will pay a higher routine home care rate for the first 60 days of care ($187 average) and a lower routine…


Hospice Cap Sequestration Update

In March 2015, CMS instructed its contractors to add sequestered funds, amounts never paid to providers, to revenue for purposes of calculating the hospice cap. This results in cap repayment demands that are overstated, in that they require repayment of funds…







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.,…