Issue in Focus: Getting Ready for Hospice Self-Reporting of the Aggregate Cap
January 8, 2015 04:48 PM
The Fiscal Year 2015 Final Hospice Payment Rule directs that, beginning with cap year 2014 each hospice must self-calculate and report its aggregate cap (along with any applicable overpayment) by not later than 5 months following the close of the cap year (March 31). Further, the self-calculation may not be completed earlier than 90 days following the close of the cap year (Jan. 31). As part of the final rule the Centers for Medicare & Medicaid Services (CMS) indicated that it would be providing by way of the Medicare Administrative Contractors (MACs), a pro-forma spreadsheet for calculation of the cap and instructions on how to calculate the cap. The calculation made by the hospice will be an interim calculation and the MACs are expected to make a final cap liability calculation at some later date.
CMS has not yet released a copy of the spreadsheet or instructions on self-calculation of the aggregate cap, but there are steps that hospices can take now to be ready for this obligation --
First, hospices must ensure that they are in active status with the Individuals Authorized Access to CMS Computer Services (IACS) system so that they will have no difficulties accessing the appropriate Provider Statistical and Reimbursement (PS & R) reports that will be required to self-calculate the aggregate cap.
Information regarding the IACS system is available here.
Secondly, hospices may want to purchase access to a recent web event hosted by the National Association for Home Care & Hospice (NAHC) titled “Mastering Financial Management and Calculation of the Hospice Aggregate Cap—What Every Hospice Provider Should Know” that fulfills the following educational objectives:
Outline the rationale behind closer scrutiny of aggregate CAP liability and the policy goals related to more timely self-reporting
Explain the need to monitor CAP status throughout the year; Describe how to effectively monitor and compute the hospice's aggregate CAP status
Secure the information necessary to prepare the annual CAP self-determination and to make this submission
Project the final CAP liability and make request for ERS
For additional information about purchase of access to this web event, please click here.