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…
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…
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…
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. As…
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…
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…
November 17, 2014 | Hospice Law By Brian Daucher In the sad history of CMS accounting games, this marks a new low. As everyone knows in April 2013, in the middle of the 2013 cap year, CMS implemented the 2% Medicare sequester…
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 about the…
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.,…