Hospice Reminder! Are You Ready to Calculate and Report Your Aggregate Cap?
Submission Deadline is March 31
February 5, 2016 03:23 PM
Beginning with the 2014 Cap year, hospices are required to annually calculate and report their estimated aggregate Cap to their Medicare Administrative Contractor (MAC) no earlier than three months after and no later than five months following the end of the hospice Cap year (the 2015 year closed on October 31, 2015). The latest a hospice may file its self-calculated aggregate Cap calculation for the 2015 Cap year is March 31, 2016. Failure to file the Cap calculation on a timely basis and address any Cap-related liability will result in payment suspension.
Early in 2015 the Centers for Medicare & Medicaid Services (CMS) began a systems change that moved access to the Provider Statistical & Reimbursement Report (PS&R) from the IACS system to the EIDM system. Difficulties with the transition created challenges for some hospice providers related to securing their PS&R data to calculate their estimated aggregate Cap for the 2014 Cap year. That transition was completed during the summer of 2015, and all hospice providers should ensure that they are registered in the EIDM system and that their account is active so that they may access their PS&R data to calculate their estimated 2015 aggregate Cap. A link to a CMS web page providing guidance on EIDM password reset and account registration is available here. For hospices whose accounts in EIDM are active, you may login here.
The National Association for Home Care & Hospice (NAHC) has been in contact with some of the Medicare Administrative Contractors (MACs) and has learned that the MACs do not anticipate a change in the manner in which hospices are required to calculate the aggregate Cap over the process that was used last year. Hospices should bear in mind that their calculation of their estimated aggregate Cap will NOT include the impact of the sequester. When the MACs finalize the 2015 aggregate Cap determinations later this year, their calculations will include the sequester. Those hospices whose estimated Cap calculations put them over the Cap, or whose estimates put them close to their allowable aggregate Cap should plan accordingly for a potential Cap liability linked to the final MAC determination later this year. The hospice aggregate Cap amount for the 2015 Cap year ending October 31, 2015, is $27,382.63.
Each of the MACs will post materials on their websites related to hospice aggregate Cap calculation requirements; hospices should follow their assigned MAC’s instructions -- particularly with respect to submission of the Cap calculation and any associated liability -- to ensure that their information is received timely.
Following are links to MAC-specific information that has been issued, along with any items of particular note:
CGS -- HOME PAGE
Hospice Cap (general information)
Instructions for Completing the Pro-Forma for Provider Self-Determination of Aggregate Cap Limitation
National GOVERNMENT Services (NGS) -- HOME PAGE
Hospice Cap: Self-Reporting InstructionsNGS provider: please note that separate submission instructions are available depending on whether you are under the J6 or JK jurisdiction -- please follow the instructions for your jurisdiction.
Palmetto GBA -- HOME PAGE
Self-Determined Hospice Cap for 2015