Simione™ Healthcare Consultants

Hospice Cap Reporting: Are You Prepared To File?

As you know, as published in the Federal Register on August 22, 2014, CMS released the new requirements for hospice cap reporting and overpayment remittances.   Effective for the Cap year ended October 31, 2014, all hospice providers will now have to self-disclose the aggregate cap calculation and remit overpayments.

The first report will be due to your MAC no later than March 31, 2015. 

Failure to file will result in suspension of Medicare payments, which can have a serious impact on cash flow. The MAC’s final Cap determination will then reconcile all data, which could potentially result in an increase or decrease of the self-disclosed calculation and calculate any inpatient liability.  

To read the full regulation go Click Here. (pages 50471-50474).

What must you do to comply?

1. Register for the Medicare IACS system Here. Here you will obtain:

  • PS&R payment information
  • Beneficiary information
  • If already registered, check your access:
    • Accounts are deactivated if the provider fails to recertify (once a year)
    • Your account password must be reset every 60 days

2. Confirm which methodology you file under:

  • Streamline or Proportional
    • Many providers merely accepted the MAC’s 2012 cap determination without realizing they were being switched from the “streamline” to the “proportional” method.

 3. Run your reports

  • Payments and beneficiary data utilized in the calculation must be generated at least 3 months after the end of the Cap year.  (i.e., Payments for services 11/1/13 to 10/31/14 should be run in the Medicare IACS system with a paid date no sooner than 1/31/15)

 4. Overpayments must be remitted back to the MAC upon filing

  • Can apply for an extended repayment schedule (ERS)

Do you know if a liability exists in your agency? Assess your agency’s situation now, so there are no surprises when you go to file.  You will then have adequate time to gather all the necessary information together apply for and file an ERS.

If you need help in filing, or have any questions please contact Tom Boyd, Vice President of Reimbursable Services, at [email protected] or 877-424-6527, or Maureen Laskowski, Director, at [email protected] or 800-949-0388.

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