Other elements on the horizon: case mix, site of service considerations.
Law- and policymakers are looking to curb abuses of Medicare’s hospice benefit and match payments disbursed with resources used, so you can expect more changes down the line.
In the shorter term, don’t be surprised to see the Centers for Medicare & Medicaid Services reduce hospice rates when the patients reside in a nursing home, says Financial consultant Tom Boyd with Boyd & Nicholas in Rohnert Park, Calif. The HHS Office of Inspector General has been hammering the hospice-nursing home reimbursement problems in a series of reports, and CMS is likely to respond with payment changes.
Further down the road, CMS may have plans to implement a case mix system similar to that for home health agencies, industry veterans predict. That system could rely heavily on diagnosis coding, and may be one reason CMS has been pressuring hospices to assign thorough diagnosis codes for their patients (see Eli’s HCW, Vol. XXI, No. 27).
First step: In its home health prospective payment system rule for 2013, CMS included a section on hospice. "We have been working on the initial development and testing of a hospice patient-level data item set," the agency said in the rule. "This patient-level item set could be used by all hospices at some point in the future to collect and submit standardized data items about each patient admitted to hospice. These data could be used for calculating quality measures."
CMS and its contractor piloted the initial item set last year. At the time, CMS said it was considering a 2014 implementation date for the data set, although observers now find that date unlikely.
Remember: This is how OASIS in the home health industry got its start, experts point out — as a quality data tool. Later, CMS used the data set for payment purposes.
Switching to a case mix system for hospice would be unlikely to occur before 2018 at the earliest, expects Tom Boyd with Boyd & Nicholas in Rohnert Park, Calif.
With so much work on CMS’s plate already, the date may be even later, guesses financial expert William "Ted" Cuppett with The Health Group in Morgantown, W.Va.
Hospice Philosophy At Odds With Case Mix System
Jay Mahoney with Summit Business Group in Penfield, N.Y. hopes CMS won’t go to a full case mix system for hospice. "A diagnostic-based case mix payment system would certainly be inconsistent with what we thought would be the best way to support the goals of hospice care in the earliest days of developing the hospice benefit," recalls Mahoney, who headed the National Hospice Organization (now NHPCO) for 14 years.
But hospices may not have much choice. "If you are looking for precision in payment policy, such an approach seems to be generating favor," Mahoney observes.
"Creating such a payment structure for hospice services in a fair and equitable manner would require an enormous effort," Mahoney tells Eli. "Providing a different approach would offer little assurance that it would be an all around better approach."
Matching resources with services in a case mix system is probably inevitable. But Cuppett laments the fact that hospice reimbursement will become more complicated under this potential methodology. That, in turn, will result in more resources spent on administrative activities related to billing and less used on direct patient care.
