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AUGUST 27, 2015  
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New Hospice Medicare Cost Reporting Forms

By: Michael Smith

In August 2014, CMS introduced Chapter 43, Hospice Cost Report (Form CMS-1984-14), which replaces the existing Form CMS-1984-99. The forms and instructions were revised in accordance with the statutory requirements for hospice payment reform in §3132 of the Patient Protection and Affordable Care Act (ACA) and to incorporate data previously reported on the Provider Cost Report Reimbursement Questionnaire, Form CMS-339.
 
The new freestanding hospice cost report forms will be required effective for cost reporting periods beginning on or after October 1, 2014. The new forms will also require the accumulation of additional hospice data. Worksheets A will now require the separate identification of patient care service costs by level of care (continuous home care, routine home care, inpatient respite care and general inpatient). Worksheet B has new general service cost centers and new statistical bases that also need to be allocated by level of care.
 
Below is a summary of the cost reporting forms:
  • Worksheet S-2 incorporates data previously reported on the Provider Cost Report Reimbursement Questionnaire, Form CMS-339
  • Worksheet A separately identifies general service costs
  • Worksheets A-1 through A-4 identify direct patient care services by level of care
  • Worksheets B and B-1 separately identify and allocate general service costs by level of care
  • Worksheet C calculates per diem costs by level of care
  • Worksheet F series provide for reporting of hospice financial data
What is changing?
The main changes to the new forms can be summarized in one phrase: All direct costs MUST BE broken out by level of care.
 
These changes may require hospices to make cost structure changes or cost allocation changes. Hospices should review their current cost accumulation systems to determine the most efficient way to accumulate/reclassify direct costs for each level of care. A majority of these changes involve the recording/tracking of personnel salaries and other costs. These changes may include one of the following:   
  • Revise the Chart of Accounts to include accounts by position/level of care
  • Continuous time recording systems
  • Time studies
  • Reclassifications (must have an auditable bases to support reclassification)
The Worksheet B and B-1 allocations may also provide new challenges. These challenges can be mitigated by working with your designated Hospice Medicare Administrative Contractor (MAC) to request and obtain MAC approval to change the bases or order of allocation for Worksheet B and B-1. Changes of this type are provided for in the Provider Reimbursement Manual 15-1, Chapter 23, §2313. These requests must be a written request to the MAC made 90 days prior to the end of the cost reporting period for which the change is to apply. The MAC has 60 days from receipt of the request to make a decision or the change is automatically accepted. The request must include all supporting documentation to establish that the new method is more accurate.
 
Hospital-based hospices should also start planning for similar changes to the Form CMS-2552. While not yet OMB approved, preliminary indications are that there will be a new worksheet series (Worksheet O) that will require the same data as Form CMS-1984-14.
 
If you have questions regarding the new hospice cost reporting forms or need assistance making a change in bases/order of allocation, please contact your Eide Bailly reimbursement representative.

   
Michael Smith
Reimbursement Senior Manager

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