Hospice Association of America Submits Comments on Revisions to Hospice Cost Report
July 18, 2013 03:03 PM
On June 28, the National Association for Home Care & Hospice’s affiliated Hospice Association of America (HAA) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its proposed revisions to the hospice cost report. HAA has long supported expanded data collection and modifications to the hospice cost report, and urged in its comments that CMS make significant modifications to the cost report and instructions prior to implementation to ensure “success…in securing the expanded data that [CMS] is seeking and hospices are not unnecessarily burdened by the changes.”
HAA noted that representatives of NAHC’s Home Care and Hospice Financial Managers Association (HHFMA) workgroup conducted a thorough review of the proposed changes.
The analyses identified concerns related to the following:
The new general services cost centers and the statistical accumulation requirements
The quality of the cost report instructions
Inconsistencies between the cost report and existing regulatory requirements under the Conditions of Participation
The cost burden of complying with the revisions
The challenges associated with meeting the stipulated method for direct costing of patient care services across the four levels of hospice care.
As part of its comments, HAA indicated that NAHC, HAA, and the HHFMA stand ready to assist in every way possible to “supply recommendations on modifications to the hospice cost report and instructions to ensure grater clarity, ease of completion, and – ultimately – greater accuracy and utility of the data.”
HAA’s comments are available for review here. Also referenced in the comments were extensive recommendations provided by members of the HHFMA.
HAA will continue its efforts to modify the proposed cost report changes. Watch for updates in future issues of NAHC Report and Hospice Notes.