HHA-based Hospice Cost Report Revisions Proposed
September 17, 2015 09:35 AM
On September 4, 2015, the Centers for Medicare & Medicaid Services (CMS) posted notice in the Federal Register seeking comment on proposed revisions to the home health agency (HHA) cost report. The revisions that CMS is proposing are an expansion of reporting of costs for HHA-based hospices by level of care (as well as deletion of obsolete information related to HHA-based Rural Health Centers, Comprehensive Outpatient Rehabilitation Facilities, and Federally-Qualified Health Centers). These changes are in keeping with the changes that CMS has put forth for freestanding, hospital and SNF-based hospices.
CMS is proposing that these changes be effective for cost reporting years beginning on or after October 1, 2015. There is a 60-day comment period on the changes, with comments due by November 3, 2015. Once CMS has reviewed any comments and made modifications, they must release the forms and instructions again for a 30-day comment period before finalizing them.
As noted in a recent NAHC Report article, cost reporting forms/instructions affecting hospital and skilled nursing facility (SNF)-based hospices are undergoing comment, as well. At this time all provider-based hospice cost reporting changes are expected to be effective for cost reporting years beginning on or after October 1, 2015. This means that all provider-based hospices should be in the process of expanding their Chart of Accounts to ensure collection of data in the appropriate detail so that they can meet the cost reporting requirements. Data from the expanded cost report will be used to assess adequacy of hospice payments and for potential future payment changes.
CMS has not yet posted the documents outlining the proposed HHA cost report changes online on its PRA Listing web page, but the National Association for Home Care & Hospice (NAHC) has secured copies of the forms, instructions and other supporting documents, which we are making available below:
Home Health Agency Cost Report Instructions
Revisions to Form CMS-1728-94 Home Health Agency (HHA) Cost Report Application/Update Form
Supporting Statement for Form CMS-1728-94 Home Health Agency Cost Report