Cost Report Update for Provider-based Hospices
Home Health Cost Report Changes Pending
September 11, 2015 03:21 PM
The Centers for Medicare & Medicaid Services (CMS) is in the process of modifying all cost reporting forms and instructions used by hospice organizations to include reporting of costs by level of care. These changes are significant and require expansion of data collection efforts and modification of a hospice’s chart of accounts to ensure costs are attributed in detail to the appropriate level of care. The first cost reporting forms and instructions that CMS modified to reflect these changes are applicable to freestanding hospice organizations and became effective for cost reporting years beginning on/after October 1, 2014. See previous NAHC Report coverage here, here, here and here.
In more recent months, CMS has requested public comment on identical revisions to cost reporting forms and instructions for hospital (form CMS-2552-10) and skilled nursing facility (SNF)-based hospices (form CMS-2540-10). The hospital-based hospice forms/instructions have gone through an initial public comment period and we are awaiting a second opportunity for comment. CMS has requested public comment twice on the SNF-based hospice forms/instructions; the second comment period for the SNF-based hospice changes ends at close of business on September 11, 2015. Relative to the second round of the SNF cost report changes, CMS posted an earlier version of the instructions and neglected to post the forms; they are in the process of correcting the posting on the website. In the interim, CMS has supplied the National Association for Home Care & Hospice (NAHC) with copies of the instructions and forms; they are available for viewing here and here. IMPORTANT NOTE: CMS’ initial intent was to make the SNF-based hospice cost report changes effective for cost reporting years beginning on/after October 1, 2014; CMS now intends for the changes to become effective for cost reporting years beginning on/after October 1, 2015. NAHC does NOT anticipate that this date will change, so if SNF-based hospices have not yet modified their chart of accounts or data collection processes, they should do so now. The expanded data collection requirements are included in a new series of cost report worksheets (Worksheet O).
On September 4, 2015, CMS published in the Federal Register a request for comment on proposed changes to the Home Health Agency Cost Report (CMS-1728-94). CMS has not yet posted the supporting documents containing the proposed changes but they should be posted at some time in the near future here. We anticipate that these changes will include the expansion of data collection and attribution by level of care for HHA-based hospice programs but do not know if the proposed changes include other revisions to the HHA cost report. As soon as the supporting documents are posted NAHC will analyze them and report on the changes. This request for comment is subject to a 60-day comment period that ends on November 3, 2015.