Home Health & Hospice Week

Stay tuned for forthcoming guidance for more details.

While hospices are relieved that Medicare walked back its proposed requirement to use a Marriage and Family Therapist and/or Mental Health Counselor in the interdisciplinary group, they still have many questions about the new MFT/ MHC provisions.

Reminder: In the physician fee schedule proposed rule for 2024, the Centers for Medicare & Medicaid Services floated the idea of requiring MFTs/MHCs for IDGs depending on a patient’s needs. But in the final rule published in the Nov. 16 Federal Register, CMS changed its tune. “The hospice IDG will only be required to include one [social worker], one MFT, or one MHC,” the rule said. “The hospice is not required to include all three of these professions as members of the IDG,” the agency clarified.

Clarification No. 1: Hospices don’t have to hire MFTs/ MHCs at all, CMS’ Mary Rossi-Coajou explained in the agency’s Nov. 29 Open Door Forum for home health and hospice providers. But if they do, the therapists and/or counselors must be direct employees.

That means “the hospice must have a W-2 for them,” Rossi-Coajou elaborated. “However, the MFT or MHC can be full-time, part-time, or per diem,” she told attendees. Alternatively, the therapist/counselor can be a volunteer as outlined in regulation, she offered.

Clarification No. 2: If the MFT/MHC works only for a hospice, they don’t need to enroll in Medicare via PECOS, Rossi-Coajou detailed. If they are serving patients outside of hospice, they will need to enroll via PECOS, she advised.

These clarifications and more will be available in forthcoming guidance, Rossi-Coajou said in the forum. CMS is working on a question-and-answer document as well as official guidance for surveyors, she revealed. The agency hopes to issue them as soon as possible before the Jan. 1 implementation date.

Other hospice issues addressed in the forum include:

• HOPE. A fall update on the tool is officially off the table. Even though the hospice final rule for 2024 noted that CMS planned to “provide additional information regarding HOPE testing results on the HQRP website in fall of 2023,” the agency is planning to stay mum on the topic until the 2025 hospice proposed rule expected next spring, CMS’ Jermama Keys revealed in the forum. A “comprehensive report” that includes beta testing info is likely close to that time, Keys said in the Q&A portion of the Zoom session.

The push is not exactly a surprise, since Keys hinted in the August Open Door Forum that HOPE dates were likely to change from the rule’s schedule (see HHHW by AAPC, Vol. XXXII, No. 31).

It does seem fairly certain that HOPE implementation will be addressed in the 2025 rule, although the implementation year is still unclear.

• Care Compare. The November refresh of hospices’ Care Compare data is now up, Keys noted. That includes the claims-based measures which are based on eight full quarters of data. Those measures won’t be updated again until next November, she reviewed.
• CAHPS. The exemption form for size for 2024 is due by Dec. 31, CMS’ Lauren Fuentes highlighted in the forum. That will affect payment rates in 2026.

The exemption form is at www.hospicecahpssurvey.org/en/participation-exemption-for-size.