On 8/6/2015, CMS issued the FY 2016 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements. The Final Rule finalized the proposals to align the cap accounting year for both the inpatient cap and the hospice aggregate cap with the FFY starting in FY 2017 and to align the timeframe for counting the number of beneficiaries with the FFY. This alignment eliminates timeframe complexities associated with counting payments and beneficiaries differently from the FFY and will help hospices avoid mistakes in calculating their aggregate cap determinations. Additionally, shifting the cap accounting year timeframes to coincide with the hospice rate update year (the FFY) better aligns with the intent of the new cap calculation methodology required by the IMPACT Act of 2014 (P.L. 113‒185).
2017 Cap Year (10/1/2016–9/30/2017)
The per beneficiary cap amount for calculating the hospice aggregate cap for the 2017 transition year will not be prorated for the shorter time frame. Instead, hospices and the HHH MACs are to count payments, count beneficiaries, and determine the percentage of inpatient days as follows for the 2017 cap year:
- The beneficiary count period for the aggregate cap determination for hospices using the patient-by-patient method is from 11/1/2016 to 9/30/2017.
- The beneficiary count period for the aggregate cap determination for hospices using the streamlined method is from 9/28/2016 to 9/30/2017, which is 12 months plus three days.
- The payment period for the cap calculation for both the streamlined and patient-by-patient methods is 11/1/2016 to 9/30/2017. This is 11 months of payments.
- For the inpatient cap, HHH MACs are to calculate the percentage of all hospice days of care that were provided as inpatient days (GIP care and respite care) from 11/1/2016 through 9/30/2017 (11 months).
2018 Cap Year (10/12017–9/30/2018)
- Hospices and HH MACs are to count both beneficiaries and payments for hospices using the streamlined or the patient-by-patient proportional methods from 10/1/2017 to 9/30/2018.
- HHH MACs are to calculate the percentage of all hospice days of care that were provided as inpatient days (GIP or respite care) from 10/1/2017 to 9/30/2018.
Any hospice that does not report its self-determined cap by February 28th will be subject to a payment suspension.
Once hospice providers have self-reported, we will send a confirmation letter within 45 days of receipt. When applicable the confirmation letter will also serve as a demand letter for the provider with an amount due the Medicare Program. We will also perform a cursory review of the submitted self-determination within 60 days of receipt.
The statutory cap amount to be used for the 2017 self-reported hospice cap calculation is $28,404.99.
For more information on Hospice Cap Reporting or to get help with your cost reporting, contact Advantage Healthcare Consulting or reach out directly at (626) 297-0094.
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