Home Health & Hospice Week

Industry Note:

Don't Forget Cap Impact When You're Hit With Takebacks

If you're a hospice provider that's been hit with an overpayment request from a Recovery Audit or other government contractor, and you've exceeded your per beneficiary cap, there may be a small silver lining.

"If a hospice is subjected to claim recover- ies and has incurred a Medicare cap overpayment ... the hospice should request recalculation of cap lia- bilities subsequent to or simultaneously with the demand for claim recovery," urges consulting firm The Health Group in Morgantown, West Virginia. "Payment of claim-related demands may constitute overpaying, in some cases double paying the Medicare program because excess payments were previously determined as part of a cap analysis and repaid to the Medicare program. Denied claims, or claim-related overpayment determinations should be used to reduce payments that were previously used to determine cap liabilities."

But while "beneficiary counts may also be reduced as a result of the claim-related denials ... generally the reduction in any beneficiary count is insignificant to the reduction in Medicare pay- ments," the firm says in its electronic newsletter.

Bottom line: "Make certain that any claim denials or claim repayments are factored into the determination of cap liabilities," The Health Group recommends.

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