Home Health & Hospice Week

A new Medicare Program Integrity Manual update should reduce potential double whammies on hospices that exceed their aggregate per-beneficiary cap.

Old way: “Historically, PI contractor re-views of hospices have overlapped with the MAC review of the benefit cap liability for those same hospices; resulting in a potential double recovery for the government,” the Centers for Medicare Services says in the manual update.

New way: Effective March 24, “upon the initiation of a hospice review, the [Unified PI Contractor] shall reach out to the MAC to determine whether the hospice is subject to any finalized or ongoing cap liability reviews (self-reported, final, and/or reopening) for the applicable period of the UPIC’s audit. If there are no ongoing/finalized cap liability determinations, the UPIC shall proceed with its review.” Then before issuing a final overpayment, “the UPIC again shall reach out to the MAC to ascertain whether ... the hospice has become subject to an ongoing/finalized cap liability determination,” the manual continues. If no, the UPIC will finalize its review, issue the findings to the hospice, and refer any overpayment to the MAC for collection. If yes, the UPIC will hold off “until the review has been completed.”

However: After the review is completed, “if the UPIC determines that there is no potential for double recovery against the hospice, the UPIC shall finalize its review and ... refer any overpayment to the MAC for collection.” If not, “the UPIC shall note the amount of the double recovery in its report and deduct that amount from the overpayment determi­nation that it refers to the MAC for collection. This process ensures that a provider is not penalized for the same beneficiary twice.”

See the manual, which also includes changes regarding investigations and identity theft, at https://www.cms.gov/files/document/r943pi.pdf.