New at Noyce Consulting — CMS overpaymentent

Help for hospice professionals suffering from regulatory whiplash

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You're likely too busy with patient care and follow up from your latest CMS-inspired QAPI project to know what Medicare plans to change in the hospice world next. Even if you had time, would you read all 140 pages of regulatory language in the the FY 2017 hospice proposed rule CMS posted April 21?
That's why I've been studying it. So I can fill you in on some important important proposals CMS published. For example:


Hospice Aggregate Cap Report & Overpayment Returns due March 31!

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Remember that hospices must calculate and report their estimated aggregate Cap to their Medicare Administrative Contractor (MAC) between three and five months after the October 31 each year. 

That makes the final deadline for the 2015 CAP report March 31, 2016. There's still time to comply. Don't risk payment suspension by filing late.


The Whats, Whens, & Hows of Repaying Agency-Discovered Overpayments to CMS

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During a spot-check quality audit, you discover that the documentation in the patient record doesn't support the amount Medicare paid for the claim. Alarmed, you search the record for any misfiled documents and ask those involved with the patient's care if key information was documented correctly. After your frantic search it is clear that Medicare overpaid your agency for the services in a payment episode several months ago.

Yikes! You know the agency must repay Medicare. But isn't it too late? Was accepting the overpayment in the first place fraudulent?