Home Health & Hospice Week

Plus: Regulation also addresses wage index, HQRP, and alternative care models.

Hospices will have to submit expanded election statements and entirely new “addendum” documents about unrelated items, if the hospice 2020 proposed rule is finalized as-is.

The Centers for Medicare & Medicaid Services proposes the changes to address concerns that hospices aren’t informing patients adequately about what they cover, indicates the rule released April 19. The rule also implies that hospices may be denying coverage of items inappropriately, or claiming them as unrelated to the terminal illness.

“While the intent is sound” for the election statement and related addendum changes, “we believe the changes will impose burdens on hospice providers that are far more substantial than CMS contemplates,” the National Association for Home Care & Hospice’s Theresa Forster tells Eli. (For more details about the proposal, see a future issue of Eli’s Home Care Week.)

Other provisions in the rule include:

• Wage index. Medicare would eliminate the one-year wage index lag it currently uses for hospice, under the rule. “CMS is proposing to use the FY 2020 pre-floor, pre-reclassified hospital wage index data for the FY 2020 hospice wage index rather than using the FY 2019 pre-floor, pre-reclas­sified hospital wage index data,” the agency notes in a fact sheet about the rule.

“There are some positive aspects to this change, including that there may be increased opportunities for hospices to address concerns about wage index values with their local hospitals before they are finalized,” Forster says. But “a more negative aspect is that using an older wage index allows hospices to plan farther ahead and prepare for any major wage index swings that lie ahead.”

•  HQRP. The rule contains a number of changes related to the Hospice Quality Reporting Program. CMS signals that it continues to work on possible claims-based quality measures, is implementing a new “iQIES” system to replace QIES, and proposes making the CAHPS survey size exemption automatic.

“Starting with FY 2022 we propose to provide an automatic exemption to any hospice that (1) is an active agency and (2) according to CMS data sources has served less than a total of 50 unique decedents/caregivers in the reference year,” the rule says. “The automatic exemption is good for 1 year and will be reassessed in subsequent years. Hospices with fewer than 50 unique decedents/caregivers in the reference year would not be required to submit an exemption request form.”

• Assessment tool. The tool formerly known as “HEART” is still under development, as CMS reported in a recent Special Open Door Forum. The tool will get a new name, however, as it is too easily confused with the Hospice Abstraction Reporting Tool (HART).
• MA/ACOs. CMS wants your two cents on how hospice should fit into “alternative care delivery models” including Medicare Advantage and Accountable Care Organizations.