HVLDL measure confusion continues to plague hospices. A five-star rating based on CAHPS scores is just one of the quality-related changes in store for hospices in 2022. So indicates the hospice proposed rule for fiscal year 2022, which the Centers for Medicare & Medicaid Services published in the April 14 Federal Register. Take a look at the quality-related provisions in the rule:
Hospice star ratings would debut “no sooner than FY 2022” and would be “based on ‘top-box’ scores for each of the eight CAHPS Hospice Survey measures,” CMS proposes. More calculation specifics are on p. 45 of the rule PDF file, and CMS plans to release even more details about the rating methodology on https://hospicecahpssurvey.org in the future.
Hospice star ratings have been in the works for years, notes the National Hospice and Palliative Care Organization.
Just because you’ll be getting a new composite measure doesn’t mean you’ll get rid of an existing one. “The HCI will complement the existing [Hospice Item Set] Comprehensive Measure and does not replace any existing reported measures,” CMS says. “Because the indicators comprising the HCI differ in data source from the HIS Comprehensive Measure, the HCI and the HIS Comprehensive Measure can together provide a meaningful and efficient way to inform patients and family caregivers, and support their selection of hospice care providers.”
More details are in a two-minute CMS video at www.youtube.com/watch?v=by68E9E2cZc. The HCI will include data such as services provided, frequency and duration of visits, and average rate of spending per patient, the video indicates. CMS plans to publicly report the measure by May 2022.
CMS shouldn’t be surprised to receive “pushback on the HCI measure,” NHPCO predicts. Providers “have expressed concerns and have many clarifying questions,” the trade group reports.
Hospices still have many questions about this measure, as evidenced by the last few Open Door Forums for home health and hospice. “Providers … have clarifying questions about the calculation of the HVLDL measure,” says Katie Wehri with the National Association for Home Care & Hospice. “CMS has stated it is consistent with the HVWDII measure calculation details and hospice providers are looking for confirmation and clarification of applying these specifications to the slightly different HVLDL measure.”
Providers may protest the measure’s narrow scope. “Any claims-based measure is going to be limited to only those services reported on claims,” points out reimbursement expert M. Aaron Little with BKD in Springfield, Missouri. “Since chaplains and volunteers are not reported on claims, we know this measure will be limited in what information it really captures regarding the level of patient engagement during the final end of life period.”
CMS plans to use any feedback for equity in future rulemaking on the topic. And CMS does note that it is exploring including SPADES in the forthcoming HOPE assessment tool (see story, p. X).