The FINAL Hospice Payment Rule was released on July 31, 2015 and addresses payment reform. Additionally, the 2016 Final Hospice Rule addresses the Aggregate Cap changes. The 2016 cap year, starting on November 1, 2015 and ending on October 31, 2016, will be updated by the 2016 hospice update percentage for hospice care. This will continue through any cap year ending before October 1, 2025. It is anticipated that the result of this change is more hospices will exceed the allowed aggregate cap and by a larger amount
2015 Aggregate Cap Value (Nov. 1, 2014 – Oct. 31, 2015) — $27,382.63
2016 Aggregate Cap Value (Nov. 1, 2015 – Oct. 31, 2016) — $27,820.75
CMS is shifting the cap accounting year for both the inpatient cap and the hospice aggregate cap to align with the federal fiscal year 10/01-09/30. The 2017 cap year will be a transitional year relative to the shift in the cap year.
For the 2017 inpatient cap will be calculated using the percentage of all hospice days of care provided as either GIP or Respite from 11/01/16 – 09/30/17 (11 months).
The aggregate cap, for hospices using the proportional method for aggregate cap determinations, agencies will count beneficiaries from 11/01/16 – 09/30/17.
For hospices using the streamlined method for the aggregate cap, agencies will count beneficiaries from 09/28/16 – 09/30/17 (12 months and 3 days).
In regard to hospices filing their self-determined inpatient and aggregate cap determinations, hospices will be required to file on or before March 31, 2017 for the 2016 cap year and on or before February 28, 2018 for the 2017 cap year.
Following are the highlights of the final rule as related to HQRP:
- New providers will be required to begin reporting quality data under for the HQRP beginning on the date they receive their CCN Notification Letter from CMS. For example, if a provider receives its CCN notification letter on November 5, the provider would need to begin submitting HIS data for all admissions that occur on November 5 and later. Since the hospice did not receive its letter until after November 1 it would not be subject to any payment penalties for the relevant fiscal year.
- Hospices must submit all HIS records within 30 days of the Event Date.
- CMS is implementing the proposed timeliness threshold requirement beginning with all HIS admission and discharge records that occur on or after January 1, 2016, in accordance with the following schedule:
- – Calendar Year 2016 hospices must submit at least 70% of required HIS records within the 30 day submission timeframe for the year or be subject to a 2% reduction to their market basket update for FY 2018.
- – Calendar Year 2017 hospices must submit at least 80% of required HIS records within the 30 day submission timeframe for the year or be subject to a 2% reduction to their market basket update for FY 2019.
- – Calendar Year 2018 hospices must submit at least 90% of required HIS records within the 30 day submission timeframe for the year or be subject to a 2% reduction to their market basket update for FY 2020.
- Hospices that have fewer than 50 survey-eligible decedents/caregivers in the period from January 1, 2016 through December 31, 2016 are exempt from CAHPS®
- CMS will add CASPER as an additional communication mechanism for disseminating notifications of noncompliance, as well as publish a list of compliant hospices on the HQRP Web site.
The Final Regulation can be found at the following link: