Home Health & Hospice Week

Follow this expert advice to sidestep SFP pitfalls.

Under the program for poor-performing hospices, top scorers — those with the highest scores under the SFP algorithm — will land on the 10 percent list that’s publicly reported, or even worse, the 1 percent that must undergo extra survey scrutiny.

SFP calculations will use three sources of data, Centers for Medicare & Medicaid Services officials explained in the agency’s Nov. 14 hospice forum reviewing the program:

1. CAHPS caregiver survey data. CMS will use the most recent eight quarters of data. When all data components are present, CAHPS will count the most at 40 percent, a CMS speaker indicated in the forum.

One of the more controversial components of the SFP algorithm, less than half of hospices have CAHPS data, CMS reports in the home health final rule that contains the SFP provisions published in the Nov. 13 Federal Register.

CAHPS measures used include Help for Pain and Symptoms; Getting Timely Help; Willingness to Recommend this Hospice; and Overall Rating of this Hospice. The former two count for more than the latter two, the CMS source said in the forum.

2. Claims data via the Hospice Care Index. When HCI data is missing, CMS will assign a proxy score based on the average. CMS will use the most recent eight quarters of data.

Medicare adopted the HCI in 2021, and it includes data on 10 areas from live discharges to per beneficiary spending to visits near death (see more details in HHHW by AAPC, Vol. XXX, No. 29). About 79 percent of hospices have an HCI figure, CMS reports in the final rule.

3. Survey data. Condition-level deficiencies (CLDs) and substantiated complaints on 11 quality-related Conditions of Participation (see box, p. 323) count toward the score. CMS will use the most recent three years of data.

The survey data will come from final decisions, post-Informal Dispute Resolution, a CMS speaker noted in the forum. Nearly 82 percent of agencies had no substan­tiated complaints in the past three years, CMS says in the final rule. And 88.3 percent of all proposed SFP-eligible hospices had no quality-of-care CLDs cited over the three years.

“We proposed to use multiple data sources to provide a comprehensive view of the quality of care provided at the identified hospices,” CMS explains in the final rule. “The compilation of these data sources illustrates areas of concern — validated/identified issues based on in-person/onsite review of a hospice to meet Medicare requirements; caregiver and public complaints about hospices not providing quality of care or not meeting Medicare requirements; and quality measures that inform the public of whether a hospice is providing expected care processes or outcomes.”

Bottom line: “We believe these are indicators of poor quality hospice care,” according to the rule.

LeadingAge, and the National Partnership for Healthcare and Hospice Innovation.

“The implementation of the poorly designed algorithm, which has been widely criticized by congressional leaders, technical expert panel participants, and hospice community and association leaders, will hinder a widely shared goal of improving sector quality,” the groups warn in a release about the final rule. “We are profoundly disappointed with this decision.”

While industry reps pursue legislative and other solutions, it’s time for hospices to buckle down to work.

Hospices should begin “keying in on opportunities to mitigate risk to stay out of the Special Focus Program,” urges consultant Angela Huff with FORVIS in Springfield, Mo. “The impact to agencies in the SFP will be substantial to operations from a workload, financial and culture stress standpoint,” she warns.

“Providers need to be really focusing on survey prep and trying to avoid the program entirely,” advises attorney Robert Markette Jr. with Hall Render in Indianapolis. The similar Special Focus Facility program for skilled nursing facilities has been brutal for those involved, Markette points out.

Waste no time, Huff stresses. “Hospice agencies should be evaluating risk now and making plans on how to navigate this program going forward if they believe there is a potential to be part of the SFP,” Huff recommends. “This is not something that you want to take a ‘wait and see’ approach.”

Ounce of prevention: “It’s much better to prepare as opposed to hope your organization won’t be included and find out you are wrong,” Huff advises. “It is critical to get ready if agencies believe that their organization is at risk to undergo this inaugural SFP,” she adds. That’s better “than to just get a knock-on-the-door surprise that no organization wants to hear.”