Posted Wednesday, July 26, 2023
Recently, CMS instructed the Medicare Administrative Contractors (“MACs”) to modify the calculation of hospice CAP liabilities for the 2022 CAP Year. The modified calculation will be made to appropriately apply sequestration for the 2022 CAP Year to the calculated CAP liabilities. CAP liabilities are reduced by sequestration applicable to the payments by which the CAP was exceeded.
Sequestration for the 2022 CAP Year was as follows:
- 0% for October 1, 2021, through March 31, 2022, claims,
- 1% for April 1, 2022, through June 30, 2022, claims, and
- 2% for July 1, 2022, through September 30, 2022, claims.
Requirements for calculation as provided to the MAC are that the MACs shall request the Provider Statistical and Reimbursement (PS&R) report needed to calculate the 2022 hospice CAP determination for the following bracket periods:
- October 1, 2021, to March 31, 2022, service payments,
- April 1, 2022, to June 30, 2022, service payments, and
- July 1, 2022, to September 30, 2022, service payments.
The recalculation does not attempt to identify beneficiaries in the three (3) separate periods. It only attempts to determine the amount of the sequestration add-back against CAP liabilities at 2%, 1%, or 0%. We do not expect significant changes in the final determination of the 2022 CAP Year liability for most providers; however, some hospices may be impacted if the CAP liability for the 2022 CAP Year, before sequestration add-back, exceeds payments received for services rendered for the period of July 1, 2022, through September 30, 2022. Recalculations of any 2022 CAP liability by the MAC should be carefully reviewed by the hospice to ensure appropriate calculation consistent with the intent of the instructions provided to the MACs.
Source: NAHC
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