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MEDPAC Reviews Hospice; Proposes Quadrupling Cap Recoveries

On December 3, 2020, MEDPAC reviewed hospice data from 2019, noting these key metrics: • Medicare payments grew just under 10% to $20.9 billion; • Hospices served 1.6 million patients, including 51% of 2019 decedents...more

CARES Act: Telehealth Allowed for Hospice Recertification/Face to Face

In the CARES Act, passed March 26, 2020, section 3706 allows hospices to conduct recertifications including face to face visits using telehealth “during the emergency period.” Trump declared a national emergency on March 13,...more

CMS Sending Hospice Cap Demands Ahead of Schedule

Hospice providers within regions administered by NGS are reporting that NGS is presently finalizing and serving out final 2019 hospice cap repayment demands. This action, which tacks on sequestration (funds never received) to...more

Coronavirus: Hospices Can Help

Our healthcare system is in just the initial stages of the Coronavirus19 crisis. Hospices have a role to play. Let’s keep it short. Here is what we need to do: Telehealth. Many hospices report that nursing homes and...more

Annual DDE Recertification Due 9/30 (And Other DDE Pitfalls)

Direct Data Entry (DDE) access is a company’s revenue lifeline: without it, hospices cannot comply with NOE filing requirements or submit claims for payment. Every hospice has DDE login rights, but many fail to recognize (and...more

Hospice False Claims: AseraCare Lost A Battle But Has Helped Win The War

Last week, the 11th Circuit Federal Court of Appeals reversed summary judgment given to AseraCare in its hospice false claims case, setting up more litigation on the question whether AseraCare’s certifications were made in...more

CMS Finalizes 2020 Hospice Rule: Big Changes Coming

On August 6, 2019, CMS finalized its 2020 hospice rule, including adopting, without substantial modification, two controversial and material changes to the hospice benefit: Rebasing payment rates to shift about $500...more

CMS Proposes To Shift Hospice Funding From Routine To Enhanced Care Days

With the FY 2020 proposed hospice rule, CMS proposes two material changes for hospice providers: • CMS proposes to shift approximately $500 million of hospice funding (2.7% of payments) from routine care to enhanced care...more

CMS Proposes To Force Hospices to Specify Unrelated Treatments

In its FY 2020 proposed hospice update, CMS proposes two changes of significant interest to providers: • Shifting $500 million of reimbursement from routine to enhanced care levels; and • Requiring providers to notify...more

PRRB Sides With CMS On Hospice Cap Sequestration – Federal Court Next

On Thursday, February 28, 2019, two years after hearing arguments in lead group cases, the Provider Reimbursement Review Board affirmed CMS’ approach to counting sequestered funds as part of provider revenue for hospice cap...more

CMS Rolls Out Provider Appeals Settlement Efforts

This year CMS is rolling out two new programs aimed, finally, at helping to settle certain types of pending provider reimbursement appeals. The programs are the Low Volume Appeals Initiative and Settlement Conference...more

Health Plans and Pharmacy Benefit Managers – Past and Future

Historically, health plans and pharmacy benefit managers (“PBMs”) have been uncomfortable neighbors. Plans provide drug coverage, but contract out the provision of such drugs to independent PBMs. PBMs in turn earn market...more

CMS Proposes Payment Reform/Cap Adjustments

On April 30, 2015, CMS released its FY 2015 Hospice Wage Index, including long anticipated payment reform and some changes to the hospice cap calculation. Comments are due by June 29. Here is an initial summary and...more

A Review of CMS' Approach to $125 Million Recoupment of Payments to Providers for Services to Incarcerated / Unlawfully Present...

CMS seeks to recover from providers $125 million in alleged overpayments for services to beneficiaries who are belatedly identified as ineligible (incarcerated/unlawfully present). In this post, Sheppard Mullin examines the...more

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