An Update on Self-Reporting of Aggregate Cap for Hospices
February 4, 2015 12:29 PM
Beginning with the 2014 cap year, hospices are required to self-calculate and report their aggregate cap, along with any cap-related liability, by March 31. Hospices may not calculate the cap prior to January 31. In the final FY2015 payment rule, The Centers for Medicare & Medicaid Services (CMS) indicated its intent to issue a pro-forma spreadsheet and instructions to assist hospices in fulfilling this responsibility. However, release of the pro forma spreadsheet and instructions has been delayed because the Department of Health & Human Services (CMS) has under legal review consideration of whether the 2% sequester - which affects hospice payments beginning with services provided on or after April 1, 2013 - should or should not be included in calculation of a hospice’s cap liability.
This issue was reported by NAHC in early Fall 2014 and discussed during the November CMS Open Door Forum. The cap/sequester issue is one that NAHC has been working on in conjunction with NHPCO and others for several months.
It is NAHC’s understanding that CMS does not plan on issuing instructions related to self-calculation/reporting of the aggregate cap until the cap/sequester issue is resolved. The timing of such a resolution is not currently known. At this time, however, there is no indication that CMS plans to delay the requirement that hospices must report by March 31.
Given these circumstances, NAHC is providing information developed for industry use that will assist hospices in estimating their aggregate cap and any related liability. PLEASE NOTE that the attached cap calculation information DOES NOT include consideration of the sequester. At this time, NAHC is advising hospices to use these materials to estimate their cap liabilities, and also to calculate their cap liabilities with inclusion of the sequester so that they know what the cap liability may be if HHS/CMS determines that inclusion of the sequester in the cap calculation is appropriate. Hospices may want to wait to submit their cap self-calculation until NAHC receives additional word from CMS on resolution of the cap/sequester issue.
If you are a hospice provider that uses a financial consultant please seek their guidance on how best to proceed with the calculation of your cap liability. NAHC will continue to post and publish any updates on this and related issues.
To view a sample self-reporting cam computation, please click here.
To view a sample letter to MACs on this issue, please click here.
To view instructions on how to complete the hospice cap, please click here.