CMS Moving Forward With Sequestration Regarding Hospice CAP - 3/11/2015

All hospice providers must submit their Aggregate CAP reports by March 31, 2015.  You will not have to include the Sequestration amounts in your Aggregate CAP Payments, but they will be included by your Medicare Administrative Contractor (Palmetto GBA, CGS or NGS) when they finalize your CAP computation in six to twelve months.  I have included a link for the Final Aggregate Hospice CAP Computation below: (Remember this is not how you will submit your Aggregate Hospice Cap.  For information on how to submit your Aggregate Hospice CAP please see our Email Alert dated March 9, 2015)

Link

http://www.palmettogba.com/Palmetto/Providers.Nsf/files/Sequestration_Hospice_Aggregate_Cap_Calculation.pdf/$File/Sequestration_Hospice_Aggregate_Cap_Calculation.pdf

Many of our clients and friends are having difficulty obtaining their PSR’s and patient counts to prepare the Aggregate Hospice CAP Reports.  As of yesterday the EIDM system was not working properly.  You can still obtain the information using the IACS system.  If you need to reset your password for the IACS system please call (866) 484-8049.  We are still using the IACS system to obtain PSR’s for our Hospice and Home Health Clients for cost report preparation.

The Email Alert dated March 9, 2015 provides instructions on how to prepare your Aggregate Hospice CAP Report.  You can also use the instructions on how to download the PSR and patient counts.  Those instructions will work in the IACS system.  If you need help in preparing your Aggregate Hospice CAP Report we can prepare it for $395.  Remember you can always call us for free to ask questions.

Hospice CAP Form Finally Approved

CMS has finalized the form to use in computing the self-determined hospice cap. The form labeled 'PROVIDER SELF-DETERMINED AGGREGATE CAP LIMITATION' is attached. Instructions for completing the form are also attached.  The form is only one page. The top section contains the cap computation. The lower section contains the certification statement. Be sure to complete both sections. 

Please note the following related to submitting the self-determined hospice aggregate cap for the period ended October 31, 2014.  The due date for submitting the form isMarch 31, 2015.  Only send the signed form (supporting information is not needed).  Current instructions do not include sequestration as part of hospice payments subject to the cap, if CMS moves forward to added sequestration payments to the hospice cap it will be done by the Medicare Administrative Contractor (PalmettoGBA, CGS, or NGS).

PalmettoGBA actually sent Hospice PSR's to their providers in late February.  CGS and NGS Hospice providers will be required to obtain their own PSR.  If a hospice does not currently have access to the PS&R system, please register for access through the Enterprise Identity Management System (EIDM) when that system is available. Providers will be required to register in the EIDM system in order to have access to their PS&R data and the Medicare Contractor will no longer be providing the PS&R data.

Link to Hospice CAP Form 

Link to Instructions 

Link to Palmetto GBA Hospice CAP Page 

Link to CGS Hospice CAP Page 

Link to NGS Hospice CAP Page

CMS Moving Forward with Value Based System for Home Health

CMS released a Fact Sheet titled "Health Care Payment and Learning Network".   This network if for the entire healthcare system, not just home health.  The aim is to move the health care system toward value-based-purchasing.   The goal for 2016 is to have 30% of Medicare payments into alternative payment models and increase this to 50% by 2018.  The Fact Sheet gives you the opportunity to become a participant in the overall Health Care Payment and Learning Network.  This will keep you up to date on CMS's plans for the future of the healthcare delivery system.  (This will not volunteer you to join the home health demonstration program described below)  You will have the opportunity to provide input in the overall health care system.

We learned of the Value Based Purchasing for home health agencies in the final home health prospective payment rules.  CMS pointed out it was looking for a demonstration program that would consist of all of the home health agencies in 5 to 8 states. (If your state is chosen you must participate). The proposal states the demonstration program would place 5 percent to 8 percent of home health payments at risk meaning your reimbursement could increase up or down by that amount.  We will be providing more information in future email alerts.  I will be presenting a session on Value Based Purchasing for home health agencies at the Cutting Edge Home Health Leadership Summit to be held in Maui, Hawaii on August 12th to 14th. 

Link to Fact Sheet 

CMS Still Has Not Issued Hospice CAP Forms

The new rules require hospices to complete their own aggregate CAP Form calculations for the period of 11/1/2013 to 10/31/2014 and to remit any overpayments. The reports are due by March 31, 2015. We have a brief paragraph below from the Palmetto GBA website. 

The website states the release of the CMS approved form to use in submitted the self-determined cap is pending.  As soon as the form is approved, we will provide and post an update to our website.  It also states that Palmetto will be sending payment and beneficiary count for all hospices served by Palmetto GBA in February. They issued instructions on how to order your PSR.  We will send further email updates when CMS releases the Final Hospice CAP Forms.

Link to Palmetto GBA webpage 

Link for PSR Instructions 

Expect More HIPAA Enforcement in 2015

All healthcare providers, suppliers, physicians, and insurers should expect more HIPAA enforcement actions from HHS Office for Civil Rights in 2015.  They have received more money in the 2015 budget and they expect to collect more fines, so we can expect more activity this year.  It is a good time to check that you are complying will all of the HIPAA Privacy Rules and Regulations.  Look at potential holes due to phones, laptops, and tablets being unsecured.  Make sure you have Business Associates Agreements will all applicable contractors who may have access to your patient information.

We will have Robert Liles speaking at our "Cutting Edge Leadership Summit" in Maui, HI in August of 2015 on the topic of "Shielding Your Company from HIPAA Violations".  We have three separate seminars. One for home health, one for hospice and one for private duty.  Make plans to attend.

CMS Moves Forward on Home Health 5 Star Rating System

Based on CMS's latest open meeting it is moving forward with its 5 Star Rating System for Home Health Agencies, but they have actually added more breadth to the rating system by adding half stars.  This will be listed on the Home Health Compare site beginning sometimes this summer. 

They propose to use 4 Process Measures and 6 Outcome Measures. 

The Process Measures:

1. Timely Initiation of Care
2. Drug Education on all Medications Provider to Patient/Caregiver
3. Influenza Immunization Received for Current Flu Season
4. Pneumococcal Vaccine Ever Received.

The Outcome Measures:

1. Improvement in Ambulation
2. Improvement in Bed Transferring
3. Improvement in Bathing
4. Improvement in Pain Interfering With Activity
5. Improvement in Shortness of Breath
6. Acute Care Hospitalization

More Information

Medicare Cost Report

Is your year end December 31 for Medicare and Taxes?  Seventy Percent of Home Health Agencies and Hospice have a year end of December 31.  This means that your Company Income Tax return is due on March 15 and your Medicare Cost Report is due on May 31.  This mean it is time to start working on Year End Reports.  If we are preparing your Medicare Cost Report you should have an email with information or will soon be receiving a letter with information.  Please call us if you have questions, we do not want you to waste time spinning your wheels and not accomplishing anything, we want it to be as painless as possible for you.   Is someone else is preparing it for you call them, they should be able to help you. Thing to consider when choosing who to prepare your Medicare Cost Report Cost report preparation experience prior to 2000 Helpfulness - Answers your questions timely Price that is affordable to your company