HOSPICE COST REPORT: Recommendations on Hospice Cost Report Revisions Submitted to CMS
October 7, 2016 02:16 PM
REMINDER: Provider-Based Hospices Must Use Revised Cost Report Starting with 10/1/2015 Cost Reporting Year
Provider-Based Hospice Cost Report News: In 2014, the Centers for Medicare & Medicaid Services (CMS) finalized revisions to the freestanding hospice cost report (CMS-1984-14) to reflect expanded requirements, including collection of cost data by level of care; the requirements became effective with cost reporting periods beginning on or after October 1, 2014. These changes are intended to support CMS’ efforts to refine the hospice payment methodology. Since finalizing form 1984-14, CMS has solicited comment on similar changes to the hospital (CMS-2552-10), home health (HHA CMS-1728-94), and skilled nursing facility (SNFCMS-2540-10) hospice cost reporting forms and instructions.
CMS has consistently maintained that these changes for the provider-based hospice cost reports would become effective with cost reporting periods beginning on or after October 1, 2015. The SNF- and home health agency-based hospice cost report changes have been finalized and displayed on the CMS Transmittals page, this week CMS has once more confirmed to the National Association for Home Care & Hospice (NAHC) that all provider-based hospices are expected to complete the revised and expanded hospice cost reporting requirements for cost reporting periods starting on or after October 1, 2015. The changes to the hospital-based cost report will likely be finalized next month. In the interim, provider-based hospices may use the SNF-based hospice forms as CMS has indicated that they mirror the hospital-based changes. NAHC will post notices to the NAHC member listservs when the final forms/instructions are posted publicly.
Following are links to the most recently available version of the hospital-based hospice cost report forms and instructions:
Hospital-based hospice forms and instructions--CMS-2552-10(under INSTRUMENT FILE column):
Experts Develop Cost Report Recommendations: In related news, a working group of hospice cost report experts drawn from NAHC’s Home Health and Hospital Financial Managers Association (HHFMA) has been meeting throughout the summer to discuss continuing concerns with the hospice cost report changes and related matters. The group developed a letter outlining a series of concerns and recommendations, including the following issues:
COST REPORT EDITS– The group recommends that certain cost report edits be returned to Level I edits to improve the quality of collected cost report data.
CONTRACTED INPATIENT COSTS AND COST REPORT ELECTRONIC REQUIREMENTS– The group maintains that contracted GIP and respite costs should not be included in accumulated costs used for the allocation of administrative-general expenses and requests a software change that would automatically remove contracted costs from the accumulated costs.
COST REPORT TECHNICAL CORRECTION FOR REPORTING OF DURABLE MEDICAL EQUIPMENT/OXYGEN FOR GIP/RESPITE PATIENTS– The group requested a technical change to the reporting forms to allow for reporting of DME/oxygen expenses on Worksheet A-3 and A-4.
COSTING BY LEVEL OF CARE– The group requested guidance on reclassification of costs by level of care to address the inability of some hospice providers to separate direct patient care service costs by level of care.
ALLOCATION OF GENERAL SERVICE COST CENTERS– The group addresses several issues of concern related to the general service cost centers. These include issues related to Dollar Value, Nursing Administration, Staff Transportation, Pharmacy, Medical Supplies (routine and non-routine), the Order of Allocation, and Requests for a Change in the Order of Allocation and Statistical Basis.
ENHANCING THE ACCURACY OF COSTS FOR INPATIENT FACILITIES – The group requests that hospices be permitted to segregate costs incurred by freestanding inpatient facilities from those incurred for other facilities.
PS&R – In light of the new two-tiered payment system, the group requests improvement to the statistics provided in the PS&R.
REPORTING VACCINE COSTS – The group requests that hospices be advised by CMS through instructions to the cost report that vaccine costs should be considered non-allowable costs.
MAC REVIEW OF SUBMITTED COST REPORTS – The group makes recommendations related to reviews by Medicare’s Administrative Contractors (MACs) of submitted hospice cost reports.
The letter has been submitted to appropriate members of CMS’ Division of Cost Reporting and the HHFMA experts group has requested a meeting to present its concerns, recommendations, and rationale to the staff at a mutually agreeable time. NAHC will keep members posted on developments in this area by way of NAHC Report.
Special thanks go to the following individuals who participated in development of the recommendations for CMS:
Mark P. Sharp, CPA, BKD LLP, Chairman, HHFMA Board of Directors
Dave Macke, CHFP, FHFMA, Von Lehman CPA and Advisory Firm, and Chair, HHFMA Payment and Reimbursement Committee
Thomas Boyd, MBA, CFE, CHFP, Simione Healthcare Consultants, LLC
Ted Cuppett, CPA, The Health Group, LLC
Tony James, Hospice Compassus
Maureen Laskowski, Simione Healthcare Consultants, LLC
Gary R. Massey, CPA, CliftonLarsonAllen LLP
Emmy Nteziryayo, Hospice Compassus