On April 4, 2024, Quantum Health Advisors highlighted the recent updates released by the Centers for Medicare & Medicaid Services (CMS) regarding Medicare hospice payments and regulatory requirements for Fiscal Year 2025. In this article, we delve into these changes, examining the key provisions of the proposed rule and their implications for hospice providers. Additionally, stay tuned as we will be hosting a webinar focused on CMS’ hospice payments and regulatory updates, where we will provide further details on how these changes may impact your organization. Details of the webinar will be announced later.
Adoption of OMB Statistical Area Delineations
One of the notable changes proposed by CMS is the adoption of the most recent Office of Management and Budget (OMB) statistical area delineations. These revisions to the core-based statistical areas, based on data from the 2020 Decennial Census, will impact the hospice wage index, potentially affecting reimbursement for hospice agencies. Hospices affected by changes to their geographic wage index may be eligible for applying a 5-percent cap on any decrease to the wage index from the prior year, providing some stability amidst potential fluctuations.
Request for Information on High-Intensity Palliative Care Services
CMS has also solicited comments from the public regarding the potential implementation of a separate payment mechanism for high-intensity palliative care services provided under the hospice benefit. This includes services such as palliative dialysis, chemotherapy, radiation, and transfusions. The introduction of a separate payment mechanism could have significant implications for hospice providers, patients, and the broader healthcare system, potentially influencing care delivery models and financial sustainability.
FY 2025 Routine Annual Rate Setting Changes
The proposed rule outlines routine annual rate setting changes for FY 2025, including a 2.6% increase in the hospice payment update percentage. This increase is estimated to result in a $705 million rise in payments from FY 2024. However, hospices that do not submit the required quality data may face a -1.4% update, highlighting the importance of quality reporting and performance measurement in ensuring adequate reimbursement.
Hospice Quality Reporting Program (HQRP) Updates
CMS is proposing significant updates to the Hospice Quality Reporting Program (HQRP), including the introduction of the Hospice Outcomes and Patient Evaluation (HOPE) instrument. HOPE will collect patient-level data at multiple time points across the hospice stay, providing valuable insights into quality of care and outcomes. Additionally, CMS is exploring the incorporation of social determinants of health (SDOH) elements into quality reporting, recognizing the impact of social factors on healthcare outcomes and disparities.
Changes to the Hospice CAHPS Survey
The proposed rule also includes changes to the Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS) Survey based on the results of a mode experiment conducted in 2021. These changes aim to enhance survey administration protocols, simplify the survey instrument, and improve response rates. Additionally, CMS is revising existing survey measures and introducing new measures, reflecting ongoing efforts to assess and improve hospice care quality from the patient’s perspective.
Hospice Conditions of Participation Technical Update: To align with payment requirements and improve clarity, CMS is proposing technical changes to the Conditions of Participation (CoPs) for hospices. These changes include updates related to the medical director, physician designee, and requirements for the certification of terminal illness and admission to hospice care. By clarifying and aligning regulatory requirements, CMS aims to promote consistency and quality in hospice care delivery.
In conclusion, the proposed rule issued by CMS provides for several material changes to Medicare hospice payments and regulatory requirements. Hospice providers and stakeholders must actively engage with the proposed changes, providing feedback and insights to inform the final rule. The final rule is expected in approximately 6 months. Please stay tuned as we will be hosting a webinar focused on CMS’ proposed rule where we will provide further details on how these changes may impact your organization. Details of the webinar will be announced later. In the interim, we are available to discuss the implications of the latest CMS announcement or any other topics of interest to you.