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The FY2020 Hospice Wage Index & Payment Rate Update & HQRP Proposed Rule was issued April 19, 2019 from the Centers for Medicare & Medicaid Services (CMS). There are significant changes to rates and election statements. The rule is summarized below with a comment period that ends at 5:00 pm June 18, 2019.

1. CMS proposes to rebase (increase) the per diem rates for 3 of the 4 hospice levels of care for General Inpatient (GIP), Continuous Home Care (CHC), and Inpatient Respite care (IRC) in order to better align payments with the costs of providing care. The rebasing takes place in the calculation prior to the current year increase of 2.7%.

 

 

 

 

2. In order to achieve budget-neutrality, which is required according to Section 1814(i)(6)(D)(ii) of the Act, CMS proposes a 2.71% payment reduction to both tiers of the Routine Home Care (RHC) rates in order to offset the proposed increases to the GIP, CHC, and IRC payment rates. This is an adjustment that, as above, takes place in the calculation prior to the current year increase of 2.7%.

CMS commented in the FY 2020 proposed rule that the modification to the RHC payment rates is not considered rebasing because it does NOT bring the RHC payment rate into alignment with the cost of providing this level of care.

 

 

 

 

3. CMS proposes to change the fiscal year used to calculate the hospice wage index to eliminate the one-year “lag” that currently exists by using the previous year’s pre-floor, pre-reclassified acute care hospital wage index. This means CMS proposes to use the pre-floor, pre-reclassified acute care hospital wage index for FY2020 instead of FY2019 to calculate the FY2020 hospice payment rates.

4. The Hospice Cap Amount has been proposed to be updated for 2020 to be $29,993.99, which include an update of 2.7%.

5. CMS proposes to modify the hospice election statement content requirements at §418.24(b) to increase coverage transparency for patients under a hospice election and facilitate communication between hospices and non-hospice providers. The additions to the election statement include:

  • Information about the holistic, comprehensive nature of the Medicare hospice benefit.
  • A statement that, although it would be rare, there could be some necessary items, drugs, or services that will not be covered by the hospice because the hospice has determined that these items, drugs, or services are to treat a condition that is unrelated to the terminal illness and related conditions.
  • Information about beneficiary cost-sharing for hospice services.
  • Notification of the beneficiary’s (or representative’s) right to request an election statement addendum that includes a written list and a rationale for the conditions, items, drugs, or services that the hospice has determined to be unrelated to the terminal illness and related conditions and that immediate advocacy is available through the BFCC-QIO if the beneficiary (or representative) disagrees with the hospice’s determination.

Additional actions for the election statement addendum proposed by CMS includes:

  • Hospices would be required to provide the election statement addendum in writing, to the beneficiary (or representative), non-hospice providers that are treating such conditions and/or Medicare contractors, if requested.
  • Hospices would be required to provide the addendum, if requested, at the time of hospice election within 48 hours and immediately if requested during the course of hospice care. If there is a request for the addendum then the presence of the signed addendum/updated addendum in the medical record would be required as a new condition for payment.
  • Hospices would be required to issue an updated addendum to the beneficiary if changes in the plan of care determine new illness or condition has arisen and must reflect whether or not items, services and supplies related to the new illness or condition will be provided by the hospice.
  • CMS includes that hospices can develop/design the addendum to meet their needs, similar to how hospice develop their own election statement however, the addendum MUST be titled, “Patient Notification of Hospice Non-covered Items, Services and Drugs” with the specific content required in the addendum outlined in the rule.
  • The Hospice election statement addendum is only required to be provided when requested for the Medicare beneficiary although, some hospices may choose to provide the addendum to all of their hospice patients.

6. As part of the proposed rule, CMS has issued a Request for Information (RFI) Regarding the Role of Hospice and Coordination of Care at the End-of-Life. CMS is requesting recommendations on ways to include hospice in other care delivery models outside of the traditional Medicare fee-for-service (FSS) which is currently the only way the Medicare hospice benefit is available.

7. Updates to the Hospice Quality Reporting Program (HQRP)-CMS is seeking input on measure concepts and/or actual quality measures along with public comment on Claims-Based and Outcome Quality Measure Development for Future years.

  • CMS has identified two “high priority” areas to be addressed by claims-based measure development: “Potentially avoidable hospice care transitions” and “Access to levels of hospice care measure”. CMS is seeking public comment on ways to further develop these two measure concepts and different measure concepts that fall under these “high priority” areas.

8. The current CAHPS survey participation requirements have been proposed to extend for all future years. In addition, CMS proposes to post information from other publicly available government data to the Hospice Compare website in the future, such as US Census Bureau, CDC, and National Institute of Health.

  • Note: As early 2020, providers will be migrating to a new internet Quality Improvement and Evaluation System (iQIES), replacing the current QIES and ASAP system for Hospice Item Set (HIS) submission and enabling real-time upgrades. Public notification of the details will begin October 1, 2019.

This proposed rule is full of items that need our attention and comments! Please do your part and comment by the deadline stated above.

HPS will be conducting a two-day workshop for HPS Alliance Members June 25-26, 2019 in Nashville, TN. This two-day workshop will address some of the greatest challenges facing hospices today! Join us for this comprehensive educational event to ensure your hospice is ready to take the changes that lie ahead.

REGISTER HERE