Applicable to: Free-Standing Hospices

Proposed New Cost Report Instructions and Forms

The Centers for Medicare & Medicaid Services (CMS) recently issued revised cost report forms (CMS-1984-14) and instructions (Pub 15-II, chapter 43). These revisions are to comply with Section 3132 of ACA which requires the collection of cost and statistical information by type of service to revise hospice payments.

These will be effective for all cost reporting periods beginning on or after October 1, 2014.

The most significant change is that Worksheet A "direct patient care expenses" on lines 25 - 46 will now have to be further broken out by Level of Care (LOC) on supplemental worksheets. These LOC include: 

• Continuous Home Care Day (Worksheet A-1)
• Routine Home Care Day (Worksheet A-2)
• Inpatient Respite Care Day (Worksheet A-3)
• General Inpatient Care Day (Worksheet A-4)

In addition, reclassifications, adjustments, and allocation statistics will also have to be tracked and disclosed by these same levels. The totals of each supplemental worksheet must add up and reconcile to Worksheet A.

CMS estimates the public reporting and recordkeeping burden for this cost report to average 188 hours per response. This includes time for reviewing instructions, gathering data, maintaining records and completing the forms. Reporting costs by level of care will be a challenge and further clarification is needed from CMS.

We are urging providers to read the revised instructions and forms and express their comments and concerns directly to CMS no later than December 21, 2013.