2015 brought a major new requirement to the front door step of Hospice agencies! All hospices, regardless of whether for profit or not, must self report aggregate cap calculations to the Medicare MAC. CMS has not yet published the promised template for making these calculations, but the deadline of March 31, 2015 for hospices to file HAS NOT changed.

The Following is some additional information about the requirement:

The Specifics of the Aggregate Cap Reporting Requirement are:

Section 418.308 is amended by revising paragraph (c) to read as follows:

§ 418.308 Limitation on the amount of hospice payments.

(c) (c) The hospice must file its aggregate cap determination notice with its Medicare contractor no later than 5 months after the end of the cap year (that is, by March 31st) and remit any overpayment due at that time. Hospices shall file the aggregate cap using data no earlier than 3 months after the end of the cap period. The Medicare contractor will notify the hospice of the final determination of program reimbursement in accordance with procedures similar to those described in § 405.1803 of this chapter. If a provider fails to file its self-determined cap determination with its Medicare contractor within 5 months after the cap year, payments to the hospice will be suspended in whole or in part, until a self-determined cap determination is filed with the Medicare contractor, in accordance with§ 405.371(e) of this chapter.

Important Dates:

  • January 31, 2015:  On or after this date, a hospice may run the Provider Statistical and Reimbursement Report (PS&R) which provides the data necessary to complete the aggregate cap self report.
  • March 31, 2015: The hospice will file a “self determined cap determination” with its Medicare contractor (MAC). The MAC will provide the instructions on where to submit the final report. If there is an overpayment, it must be remitted with the aggregate cap self report, unless the hospice files a request for an Extended Repayment Plan.
  • Later date:  The MAC will provide a final cap reconciliation at a future date. No timetable or time limits are available on the timing and process of this final report.

Consequences of Not Filing or Late Filing:

If a provider does not submit an aggregate cap self report by the March 31, 2015 deadline, the hospice’s Medicare payments will be suspended in whole or in part.

How does my Hospice Request the PS&R Report?

Hospices are required to register in the Individuals Authorized Access to CMS Computer Servcies (IACS) and obtain a user name and password. However, the IACS system is transitioning to a new system, Enterprise Identity Management System (EIDM) on February 9, 2015. If you have not already secured your user name and password in the IACS system, it is now too late to do so in the IACS system. It will be best to wait until the new EIDM system is functioning, after February 9, 2015. Pay special attention to getting log in credentials so that you can access your PS&R report

If your hospice is a member of NHPCO or NAHC there are additional tools and information on their websites.

All hospices should check the Medicare MAC websites for additional information, as well!