A Status Update on the Hospice Self-Calculation of the 2014 Aggregate Cap
February 13, 2015 05:20 PM
Beginning with the 2014 cap year - November 1, 2013 – October 31, 2014, all hospices are required to self-calculate their aggregate caps using data accessed no sooner than January 31, and submit the calculation and any overpayment to their assigned Medicare Administrative Contractor (MAC) by March 31. As part of the final fiscal year 2015 hospice payment rule, the Centers for Medicare & Medicaid Services (CMS) indicated that it would provide a pro-forma spreadsheet to calculate the cap, as well as instructions to providers so that they would have guidance on the appropriate steps to take.
However, some months back issues arose related to how the cap and the 2 percent sequester, which went into effect in April 2013, interact. Additionally, there was some concern over whether a hospice’s aggregate cap calculation should include the amount of the sequester. CMS and its parent, the Department of Health and Human Services (HHS), have had this issue under scrutiny for some time. CMS has determined that it was inappropriate to issue the cap calculation spreadsheet and instructions without a final determination of whether the cap calculation should include or exclude the sequester.
Representatives of the National Association for Home Care & Hospice (NAHC) have had several communications with CMS this week and understand that a decision has been made on whether the cap calculation should include or exclude the sequester. CMS cannot reveal the final decision until after a formal notice has been sent out to the MACs. Here’s the most recent plan relative to the how the process is expected to unfold:
Some time during the week of February 16: CMS hopes to send notification to the MACs including instructions and the pro-forma spreadsheet for calculation of the aggregate cap. Please note that February 16 is a federal holiday.
Once the MACs receive information from CMS, they will need to develop their own materials to send to hospice providers and post on their websites. Some of the MACs will be establishing special means for providers to submit the cap calculations – including special post office boxes and instructions for electronic submission.
To date, Palmetto GBA has put out extensive information for its providers earlier today. They suggest that providers wait for the CMS form to submit their cap calculation but also provide information about reports Palmetto will be supplying to its Hospice providers this month to assist with the cap self-calculation responsibilities.
The Palmetto information is available here.
As NAHC secures additional information on this issue, it will be transmitted to NAHC members through the NAHC member listservs as well as through future issues of NAHC Report.
In the meantime, the transition of the PS&R application - reports from PS&R are needed for hospices to calculate their aggregate caps - from the IACS system to the EIDM system has hit a snag. CMS hopes that the problems will be resolved this weekend.
Until those issues are resolved, hospice providers can access their PS&R through the IACS system. Please note that any hospice provider that was not active in the IACS system prior to the start of the IACS to EIDM transition cannot apply for a new account or access the PS&R.
NAHC has concerns that delayed notification from the MACs on self-calculation of the cap due to the sequester issue, coupled with systems transition snags due to unanticipated problems during the IACS to EIDM transition, may create serious issues for those hospices that are not active in IACS at this time.
NAHC will be monitoring this issue closely and reporting as additional information becomes available.
Following are additional links that may be of interest to you:
CMS site notice that PS&R transition from IACS to EIDM is delayed until further notice.
NGS notice about self-calculation of aggregate cap.