CMS Makes Changes to Hospice Cost Report

By Ted Cuppett, CPA, Director of The Health Group.

On February 25, 2022, the Centers for Medicare & Medicaid Services (CMS) revised the Hospice Cost & Data Report (Transmittal R5P243i) to add a new non-reimbursable cost center to accumulate costs associated with suicide accomplished with aid of a physician in those states that allow assisted suicide.

In accordance with federal law, funds cannot be used to provide or pay for any health care item, service, or health benefit coverage for the purpose of causing, or assisting to cause, the death of an individual including mercy killing, euthanasia, or assisted suicide.

These costs, where incurred, must be segregated and reported in the new cost center for cost reporting years ending on or after February 28, 2022. Because these costs are non-reimbursable, they should be excluded from allowable costs on cost reports for earlier reporting periods even though a separate cost center was not provided on the cost report.

The following states, and Washington D.C., have authorized medical aid in dying:

  • Oregon
  • Washington
  • Montana
  • Vermont
  • California
  • Colorado
  • Hawaii
  • New Jersey
  • Maine
  • New Mexico

Additionally, hospices are not required to separately report Volunteer Coordination costs during the period of the Public Health Emergency. The volunteer coordination requirements under the Conditions of Participation have been temporarily waived. The Health Group recommends that hospices continue to report Volunteer Coordination costs as incurred, even though the requirement has been waived.