As we close out 2024, Hospice has had a roller coaster ride for sure during this year and that will continue into 2025.
The Value-Based Insurance Design (VBID) Model saw some dramatic changes going into 2024 and as a result of all the plans that withdrew from the model amongst other things, it was determined that the VBID Model would end December 31, 2024. Keeping in mind that any patients on service January 1, 2025 that were enrolled in a VBID participating plan, their hospice care will be paid by Traditional Medicare beginning with January 2025 claims.
We also began 2024 with a final rule regarding the Hospice Special Focus Program (SFP), but with uncertainties as to when the program would begin. In December 2024 there was a release of the worst 50 Hospice scorers in the SFP calculations. These 50 hospices will begin the 18 months of surveys every 6 months as a result of their scores. This list is on public display. As the 18 months progress, there will be status updates on the website as to the status of each.
During 2024, hospices continued to allow Face-to-Face encounters to be conducted via telehealth as an extension of the Public Health Emergency waivers granted through December 31, 2024. On December 21, 2024, Congress passed the American Relief Act of 2025. This Act included a temporary extension of the allowance for telehealth Face-to-Face encounters for both home health and hospice. This extension is set to expire March 31, 2025.
The CAHPS Hospice Survey has received an overhaul in 2024 that will be implemented beginning in April. Many changes were made including deleted items and some were added and some re-worded. Measures that result from the CAHPS data have also been revamped. Hospice should ensure that they are distributing the new survey beginning January 1, 2025.
Another turbulent event that impacted hospice was the implementation of the PECOS requirement for all certifying practitioners in hospice. Any physician serving as a certifying or attending physician of a hospice patient must be enrolled or opted out of the PECOS system.
Additional changes have occurred in 2024 regarding the BFCC-QIO information. Kepro had a name change to Acentra, and this requires that all information/documents that are communicating the BFCC-QIO information to a patient have that name change included. In addition, a new Notice of Medicare Non-Coverage Form has been released that includes an expiration date of 11/2027. This new form must be implemented January 1, 2025.
As a part of the 2025 Hospice Final Payment Rule there were multiple changes that will impact reimbursement. The payment rates and the Hospice CAP received an increase of 2.9%. There was a significant revamping of the CBSA classifications and wage index allocations. Hospices will need to ensure that their EMR system is billing with the correct CBSA code based on the new classifications.
The HOPE tool has now been finalized in 2024 and will be fully implemented October 1, 2025. This gives your hospice the opportunity to educate staff over the next few months to ensure a smooth transition from the HIS to the HOPE.
Lastly, Hospice medical review has continued to escalate in 2024 and there is no hint that it will be slowing down. Pre-payment reviews are being implemented on all newly Medicare Certified Hospices or ones that have a significant change in ownership. There has been a surge of UPIC, SMRC and TPE audits. Hospices must be more diligent than ever in confirming that all patients meet criteria for admission and all documentation supports that eligibility.
HPS is here to assist with any and all challenges that your hospice may be facing as we begin 2025. Being proactive within your hospice will prohibit many of the negative consequences that may result from lack of diligent reviews. Reach out to us to learn how we can assist you in being fully prepared for what’s ahead.
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