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Hospice Reminder! Are You Ready to Calculate and Report Your Aggregate Cap?

Tuesday, January 31, 2017  
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Hospice Reminder! Are You Ready to Calculate and Report Your Aggregate Cap?

Submission Deadline is March 31

Background:  Beginning with the 2014 Cap year, hospices have been 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 2016 year closed on October 31, 2016). Hospices may not use patient count data secured prior to January 31 to self-calculate their aggregate, and the latest a hospice may file its aggregate Cap calculation for the 2016 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.

Access your PS&R:  In order to calculate and self-report the aggregate Cap, hospices must secure patient count reports from the Provider Statistical & Reimbursement Report (PS&R), now located in the Centers for Medicare & Medicaid Services’ (CMS’) EIDM system.  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 2016 aggregate Cap. A link to a CMS web page providing guidance on EIDM password reset and account registration is available here.

The National Association for Home Care & Hospice (NAHC) does 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 2016 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 2016 Cap year ending October 31, 2016, is $27,820.75.

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.

NGS:  It is anticipated that NGS will publish updated information in the near future

Looking Forward:  Hospices are reminded that CMS is in the process of aligning the hospice Cap years with the federal fiscal year.  The 2017 Cap year will end on September 30, 2017.  Since self-reporting is required no sooner than 3 months and no later than five months following the end of the Cap year, the reporting deadline for self-reporting of the 2017 preliminary Cap calculation will be February 28, 2018.

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