Hospice Payments to Increase $180 Million in 2018, Quality Data to Be Posted Publicly Later this Month

On Tuesday, August 1, 2017 the Centers for Medicare and Medicaid Services (CMS) issued the federal fiscal year (FY) 2018 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements final rule. In the rule, CMS finalizes a proposal to update payments by 1% for FY 2018, which is expected to increase total payments to hospices by approximately $180 million. This increase was mandated under the Medicare Access of CHIP Reauthorization Act of 2015 (MACRA).

If you have questions about how this final rule could impact your business or product please contact us at (202) 588-5272 or jscott@appliedpolicy.com.

Hospice care is a comprehensive, holistic approach to treatment that recognizes that the impending death of an individual and, upon his or her choice, warrants a change in the focus from curative care to palliative care for relief of pain and for symptom management. Medicare hospice care is palliative care for individuals with a prognosis of living 6 months or less if the terminal illness runs its normal course. Medicare provides a per diem payment in one of four rate categories of hospice care (routine home care (RHC), continuous home care (CHC), inpatient respite care (IRC), and general inpatient care (GIP)), based on each day a qualified Medicare beneficiary is under hospice care. This per diem payment is to include all of the hospice services and items needed to manage the beneficiary’s care. In FY 2016, Medicare spent approximately $16.5 billion on hospice care and expenditures continue to increase. CMS finalized the proposed per-diem rates as follows:

FY 2018 Hospice Finalized Per-Diem Rates

No Major Changes to Hospice Quality Reporting Program, Measure Data to Be Publicly Posted on the Hospice Compare Website Later this Month

CMS also finalized changes to the Hospice Quality Reporting Program (HQRP) that aim to ensure high quality, accessible care, without added burden. Hospices are required to annually report quality measures for the HQRP and those that fail to meet quality reporting requirements receive a 2.0 annual percentage point reduction to their payments. In this final rule, CMS finalized eight measures from CAHPS Hospice Survey data which were already submitted by hospices (two global measures and six composite measures). An outline of CMS’ plans to publicly display quality measure data via the Hospice Compare website later this month, in August 2017, was also discussed in the rule.

Hospice Quality Reporting Program Submission Exemption Extended from 30 to 90 Days

For FY 2019, CMS finalized that it will extend the period of time a hospice may have to submit a request for an extension or exception for quality reporting purposes from 30 calendar days to 90 calendar days after the date that an extraordinary circumstance occurred. This change aligns the HQRP with the other post-acute care quality reporting programs, as well as the Hospital Inpatient Quality Reporting Program, and provides additional time for providers to focus on operations related to patient care should a situation arise, such as an unforeseen environmental emergency.

Hospice Evaluation & Assessment Reporting Tool (HEART) Remains Under Development, CMS Continues Work on Adjusting for Socioeconomic Factors

As CMS continues to work on adjusting quality measures to provide for socioeconomic factors, in the hospice space they continue developments on their patient assessment tool, the Hospice Evaluation & Assessment Reporting Tool (HEART). Although it was proposed that, beginning January 1, 2018 hospices would be required to submit at least 90% of all required hospice item set (HIS) records within the 30-day submission timeframe or be subject to a 2% reduction in payments in 2020. CMS received public feedback on considering this revised data collection instrument and continues to develop it at this time. This patient assessment tool differs from the current chart abstraction tool by taking into account the unique aspects of hospice care delivery including symptom burden and psychosocial needs, patient and family preferences, care of imminently dying patients, and the complexity of providing hospice care in multiple settings and at multiple intensity levels.

CMS Responds to Comments about the Source of Clinical Information Used in Certifying Patients

In the proposed rule released in late April 2017, CMS had requested input from stakeholders about the source of clinical information that is used to certify patients for hospice. The proposed rule also discussed a potential proposal that changed regulatory text to clarify that documentation used for initial certification have to come from the records of the referring physician or acute/post-acute care facility. CMS had also discussed initial face-to-face visits by the hospice medical director or physician designee to support the clinical documentation required to accompany certification of terminal illness.

The final rule discusses comments that CMS received. The majority of the comments received by CMS expressed concern that getting documentation from outside physicians and facilities would delay hospice admission and services. Commenters also expressed concern that CMS was considering requiring face-to-face visits. In its response, CMS states that the comment solicitation was intended to clarify the source of information that was already required to be review by the hospice medical director so therefore, the information can be obtained orally from the referring entity and documented in a patient chart within the 2- day time frame for certification.  In addition, CMS clarified that face-to-face visits before the third benefit recertification period would not be required and that soliciting comments was to determine whether such optional visits could be useful to support clinical documentation.

CMS did also note that they received a few comments supportive of the potential proposal.

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