When confronted with a complaint, allegation or event that implicates a potential Medicare overpayment, hospices have an affirmative duty under the federal 60-day repayment rule to conduct an investigation and refund any overpayment. In this episode, Husch Blackwell’s Meg Pekarske and Andrew Brenton share tips and tools for conducting internal investigations and determining when an
Strategic Restructuring for the Future: Exploring How Hospices Are Using Joint Ventures, Mergers and Acquisitions, and Service Diversification to Transform
Change, transformation, disruption: whatever you want to call it, it’s happening in the hospice industry over the next 5 years. It is unquestionable that the carve-in to Medicare Advantage, the rise of value-based care and steady market consolidation is changing the playing field. How do hospices respond? In this series, we explore how hospices are and can restructure their businesses. We discuss the opportunities and limits of different models: palliative care, affiliations for payor contracting or the more transformative change brought through a merger or acquisition. While there is no one-size-fits-all approach, hospices can explore new ways of being. We are excited to guide you on this road and hope these conversations help as you explore these important questions within your organization and determine your best path into the future.
By October 1, 2021, hospices will need to update their election addendum form to address a change made by the Centers for Medicare & Medicaid Services (CMS) in the final rule. The government has provided much-needed clarification and flexibility to certain aspects regarding the addendum. When should hospices provide the addendum to patients? What should hospices do if a patient refuses a signer’s discharge prior to signing the addendum? In this episode we answer these questions and discuss other key changes related to the addendum announced in the final rule: https://bit.ly/3zx5SGJ
After nearly half a year of silence, the U.S. Department of Health and Human Services finally provided direction on when providers need to submit Provider Relief Fund (“PRF”) compliance reports. In this episode, Husch Blackwell’s Meg Pekarske and Andrew Brenton discuss this and other PRF developments, including new deadlines by which providers must use their
The “rules of the road” for Provider Relief Funds continue to evolve. Recent actions by Congress and the U.S. Department of Health and Human Services provide further clarification in key areas that are helpful to hospices. In this episode we analyze the latest developments and share insights on calculating lost revenue and preparing for compliance reporting when it arrives. Tune in here: https://lnkd.in/eyr7q6c
September was another busy month as hospices and other providers try to keep pace with the government’s constantly evolving rules and standards around various COVID-19 federal relief programs. In this episode, Meg Pekarske, Tom O’Day and Andrew Brenton hone in on recent key changes to the Families First Coronavirus Response Act (FFCRA) paid leave requirements and Provider Relief Fund compliance reporting requirements, and discuss what these changes may mean for hospices. Tune in at: https://lnkd.in/ecgV5xD
On September 19, 2020, the U.S. Department of Health and Human Services (HHS) released long-awaited details about upcoming reporting requirements for certain providers that accepted funding of one or more payments exceeding $10,000 from the Provider Relief Fund (PRF). Key aspects of HHS’ new PRF reporting guidance are summarized in today’s legal alert.
The hospice industry expressed collective disappointment when the Centers for Medicare & Medicaid Services declined additional time for implementing new election statement and addendum requirements. On October 1, 2020, hospices will need updated forms, processes and training to address new payment conditions. In this episode, Meg Pekarske and Andrew Brenton review the new rule’s key
Under new guidance from the U.S. Department of Health and Human Services (HHS), hospices and other providers who received CARES Act Provider Relief Fund payments can hold off on filing their first quarterly compliance report, slated to be due on July 10, 2020.[1] Instead, HHS states that it will develop its own report and this report itself will contain “all information necessary for recipients of Provider Relief Fund payments to comply with” the quarterly reporting requirements under the Relief Fund Terms and Conditions.
After the U.S. Department of Health and Human Services (“HHS”) automatically distributed $30 billion to providers as Tranche #1 Relief Fund payments based on 2019 Medicare fee-for-service payment data, HHS subsequently released a new formula that was based on 2018 “program service revenue” and intended to calculate providers’ payments under Relief Fund Tranches #1 and #2 cumulatively. For providers whose Tranche #1 payments alone exceeded their expected payment under the new “program service revenue” formula, there have been ongoing questions about whether such providers were “overpaid” and needed to reject and return their Tranche #1 payments.