NAHA – Independent Hospice Advocates
Sheppard Mullin Hospice Law Blog: MACs issue FY2013 Hospice Cap Demands With Sequestration; Group Appeal Now Open
Hospices in the Palmetto regions have begun receiving FY 2013 cap demands that include sequestration (money never paid to the hospice) as a part of a cap revenue under CMS’ new policy. Other MACs are expected to follow shortly. As noted in our prior blog posts, CMS’ new policy to include sequestration appears to be unlawful and contrary to statute. CMS declined to ask Congress to change the cap statute, declined to modify its own regulations, and even declined to issue a public Change Request. Instead, CMS dictated this change privately to the MACs and let them announce the new “policy”.
If you receive an FY 2013 cap demand from your MAC, you will see that on the calculation page the MAC adds sequestration (money never paid) to revenue, thereby overstating hospice revenue and, in turn, overstating the repayment demand you will face.
Hospices must be alert. Each hospice that receives an FY 2013 or FY 2014 cap overpayment demand from its MAC must file an appeal within 180 days of receipt of the demands from the MAC.
From NAHA: 2014 Hospice Cap Self-Report Instructions and Forms
During the first week of March, Medicare contractors Palmetto and NGS began emailing 2014 Aggregate Hospice Cap self-reporting instructions and forms, and in some cases are mailing individual hospice data, to hospices. Some emails include samples of calculations that the MACs intend to make that will add back some or all sequestered revenues to the 2014 Cap calculation. See links below:
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