Medicare Compliance & Reimbursement

Tip: Expect quality reporting changes.

There’s no doubt hospices will find the proposed 2.3 percent payment increase the biggest news in the fiscal year (FY) 2022 rule. However, there are a few other critical proposals you may want to consider as you prepare for next year.

Take a look at five other takeaways from the hospice proposed rule, published in the Federal Register on April 14:

1. CoPs and competency training: As COVID ramped up last year, the Centers for Medicare & Medicaid Services (CMS) issued a myriad of waivers to help providers during the public health emergency (PHE). The agency now proposes in the rule that one of the waivers, which allows hospice aides to gain care competency by practicing with pseudo-patients, be made permanent. This change would impact hospices’ conditions of participation (CoP) evaluation standard, the proposed rule indicates.

2. CoPs and aide deficiencies: In a corresponding hospice CoP proposal, CMS looks at permitting hospices “to focus on the hospice aides’ specific deficient and related skill(s) instead of assessing multiple areas within the competency evaluation,” a CMS fact sheet adds.

3. Quality updates: The rule is chock full of Hospice Quality Reporting Program (HQRP) proposals. Here’s the breakdown:

• CMS aims to add a “Hospice Care Index” measure to the HQRP with 10 indicators of quality based on claims data. “The indicators represent different aspects of hospice care and aim to convey a comprehensive characterization of the quality of care furnished by a hospice,” the fact sheet notes.
• The rule also looks at introducing Consumer Assessment of Healthcare Providers and Systems (CAHPS) Hospice Survey Star ratings on Care Compare. 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 indicates.
• “The rule proposes the addition of the claims-based Hospice Visits in the Last Days of Life (HVLDL) measure for public reporting,” mentions the fact sheet. The agency hopes the addition of this proposed measure will allow for more hospice transparency.
• CMS wants to nix the seven individual Hospice Item Set (HIS) measures. Why? It has another measure — the Hospice Comprehensive Assessment Measure (NQF # 3235) — already available and in public reporting rotation to better ensure patients get a “holistic comprehensive assessment,” the rule says.
• CMS also has a Hospice Outcome and Patient Evaluation (HOPE) assessment instrument update in the works.

4. Health IT: CMS wants to boost data exchange in the hospice arena and is seeking the public’s input. The agency issued a request for information (RFI) on a proposed future HQRP measure related to providers’ use of Fast Healthcare Interoperability Resources (FHIR) to coordinate care and share data.

Heads up: Since the RFI touches on FHIR policies already mandated in other areas of Medicare, hospices may want to weigh in and be part of future decision-making (see Medicare Compliance & Reimbursement, Vol 46, No. 12).

5. Health equity: As healthcare continues to evolve to address COVID-19, health equity has become a major focus area for the feds. CMS offers another HQRP-focused RFI, aligning with parallel federal outreach on solving healthcare inequities. The RFI seeks feedback on the intersection of quality care, patient satisfaction, and provider accountability, the fact sheet suggests.

Resource: Review the proposed rule in the Federal Register at www.govinfo.gov/content/pkg/FR-2021-04-14/pdf/2021-07344.pdf and comment by June 7.