Hospices wondering whether to include sequestration funds in their aggregate cap calculations are still up in the air. Cap calculations and any resulting overpayment amounts are due March 31 (see Eli’s HCW, Vol. XXIV, No. 5).
But a spreadsheet and instructions from CMS have been delayed “because the Department of Health & Human Services (CMS) has under legal review consideration of whether the 2 percent sequester … should or should not be included in calculation of a hospice’s cap liability,” reports the National Association for Home Care & Hospice in its member newsletter.
NAHC suggests calculating your cap with and without the sequestration amounts so you can anticipate liability if CMS does require inclusion of sequestration dollars in the calculation. Hospices may want to wait to submit their cap self-calculation until CMS resolves the issue, but by March 31, NAHC offers.