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As a response to the Consolidated Appropriations Act of 2021, the Hospice Special Focus Program was created to identify hospices who have poor quality outcomes based on quality indicators.

A technical expert panel collaborated with CMS to establish the most effective approach for conducting the Special Focus Program and its content. While there are concerns, the reality is that they are moving forward with the program. As they continue implementing the program, CMS has confirmed that they will monitor the process and make changes as needed.

The selection process will begin in 2024. During this process, data from previous years’ Hospice quality information will be gathered, and a group of hospices will be chosen for the audit process. These selected hospices will participate in the program for 18 months. Throughout this period, surveys will be conducted every six months. Based on the findings of these surveys, the hospices will either successfully graduate from the program or have their Medicare certification terminated.

During the selection process, all Hospices who have the following qualifications will be considered for the program:

  • Medicare Certification
  • Serve Hospice patients in the United States and its territories
  • Have at least enough data for one of the indicators in the algorithm
  • Have filed a claim within the previous 12 months

Next, CMS will proceed with the algorithm calculation. The initial step involves assessing the number of condition level deficiencies the Hospice has received within the last 36 months. Additionally, they will consider whether there have been any substantiated complaints. It’s important to understand that only complaints that have been substantiated will be considered.

In addition, they will examine the Hospice Care Index (HCI), which is determined based on 10 specific items extracted from your claims. Furthermore, they will consider four specific measures from the Hospice CAHPS surveys.

During the algorithm calculation, they will use estimates or averages in certain instances where a Hospice is lacking a specific piece of data. However, when it comes to the CAHPS Hospice surveys, the algorithm will remove CAHPS Hospice survey data completely when the Hospice does not have survey information.

Smaller hospices are exempt from participating in the CAHPS Hospice survey protocols, and as a result will not have a score.

After hospices are subjected to the algorithm, they will be assigned scores. These scores will be arranged so that the highest scores represent the worst performance. The top 10 percentile of hospices with the worst scores will be considered as the pool from which CMS will make their selection. At this point, it is unknown how many hospices will be chosen. However, once the selections are finalized, the information will be publicly disclosed on the Special Focus Program website.

Hospices need to be aware that if they have experienced a Condition Level Deficiency in the last 36 months, it significantly increases their chances of being selected for the program. Once selected, Hospices will be a part of the Special Focus Program for 18 months, and will undergo a survey every six months. The surveys must be conducted exclusively by state survey organizations and cannot be carried out by any accreditation entity such as CHAP, ACHC, or JCAHO.

The State Survey Office will conduct audits during the course of the Special Focus Program. If a Hospice passes two surveys within the span of their time in the program without Condition Level Deficiencies or immediate jeopardy findings, they will graduate from the program. Hospices that do have Condition Level Deficiencies during these surveys that are unresolved will result in their termination from the program.

We highly encourage you, particularly if you have encountered any Condition Level Deficiencies within the last 36 months, to promptly review all of your data that will be reviewed by a surveyor. It is crucial to ensure that you are on the correct path to successfully navigate through an audit, should one arise.

Should you need assistance through this process, HPS Consultants are experienced in conducting mock surveys, and would be happy to assist and answer questions you may have. Please feel free to reach out to us.

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