CMS Releases Spreadsheet, Instructions for the Self-Calculation of Aggregate Cap for Hospices
Hospices Must Submit Calculation by March 31
March 4, 2015 10:32 AM
A provision of the FY2015 final hospice payment rule requires that, beginning with the 2014 cap year, each hospice must self-calculate its aggregate cap and submit it to its Medicare Administrative Contractor (MAC) within five months of the close of the cap year (along with any associated overpayment) or risk suspension of payment. A final determination of a hospice’s aggregate cap liability will be calculated by the hospice’s MAC at a later date. On March 2, the Centers for Medicare & Medicaid Services (CMS) released the long-awaited spreadsheet and instructions for use by hospices for self-calculating their 2014 aggregate cap.
Release of the cap self-calculation spreadsheet had been delayed as CMS and the Department of Health & Human Services (HHS) resolved the most appropriate method for addressing the 2% sequester as part of the overall cap determination. CMS is not requiring that a hospice take the sequester into consideration as part of its initial cap self-calculation; rather, the hospice’s MAC will incorporate the sequester as part of the final cap liability determination at a later date.
Hospices should anticipate that their MACs will be circulating the pro-forma spreadsheet and instructions for self-calculation of the aggregate cap in the very near future, along with specifics as to where hospices should send their cap spreadsheets and any overpayment. In order to complete the spreadsheet, hospices must secure information from the Provider Statistical & Reimbursement Report (P S & R) system. However, since late January CMS has been transitioning the P S & R application from the IACS system to the EIDM system; throughout this time period providers have been unable to register to secure access to the P S & R, so unless a hospice was in active status prior to the beginning of the transition, it cannot gain access to the P S & R application at this time.
Palmetto GBA recently issued letters to its hospice providers containing the data that will be needed to complete the cap self-calculation. In addition, Palmetto has posted additional information regarding the cap self calculation and submission, which can be found here.
It is NAHC’s understanding that while neither National Government Services (NGS) nor CGS plan to issue letters containing the P S & R data needed to self-calculate the cap on a jurisdiction-wide scale, both NGS and CGS will consider requests from individual hospice providers for the necessary P S & R information on a case-by-case basis. It is also anticipated that NGS and CGS will be posting additional information on their websites in the very near future.
CGS hospice providers who do not have access to their P S & R reports may submit a request to CGS for the cap data by contacting the CGS General Provider Contact Center at 877-299-4500 (select Option 1) and a referral will be made to the CGS Provider Audit department.
NGS providers who do not have access to their P S & R reports may submit an email requesting the information to PS&R@anthem.com.
Following are links to information that was released from CMS earlier today:
CMS’ pro-forma spreadsheet for self-calculation of the aggregate cap is available here.
CMS’ instructions for Pro Forma self-determined aggregate cap calculation available here.