CMS Releases Proposed FY 2017 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements
Friday, April 22, 2016
by: Visiting Nurse Associations of America

Section: Public Policy and Advocacy

Late Thursday, the Centers for Medicare & Medicaid Services (CMS) released the proposed Fiscal Year (FY) 2017 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements. VNAA is currently reviewing the recommendations in the proposed rule and will offer a webinar on our analysis, as well as soliciting member feedback. 
In the meantime, we would like to share some of the key elements highlighted in the proposed rule.
The Net 2 Percent Increase 
While VNAA supports CMS' proposal to increase the payment rate for 2017, we continue to be concerned about increasing costs associated with workforce recruitment and training, supplies and technology, which are all rising faster than reimbursement and do not account for the increased administrative costs of the new quality measurement reporting.
Part D Medication Costs - "Double Billing"

The proposal addresses costs of pharmaceuticals that CMS believes should be part of the hospice payment that are billed outside of the hospice benefit to Part D. There is renewed attention being paid to this issue by both CMS and Congress.

Continued Concern Over Hospice as a "Long-Term Benefit"
The proposed rule highlights the potential for cherry-picking those who would need longer periods of hospice care that might not be truly eligible for the benefit at the time that they are admitted. We will be working working with members to get their feedback and experience on those who are staying in hospice longer than 180 days to a full year.
Quality Measures
Composite Process Measure: Assessment at Admission
The seven measures making up the composite measurement have already been developed and are in use: patients treated with an opioid who are given a bowel regimen, pain screening, pain assessment, dyspnea treatment, dyspnea screening, treatment preferences and beliefs/values addressed.
CMS has four quarters of data on this measurement and is currently in the analysis stage. According to them, "everyone is doing well."

The proposal differs from what CMS originally set forth in that it seeks to compile all seven measures instead of collecting seven individual measures. It is CMS' hope this will limit the variability between agencies. However, true specifics to the measures, methodology and inclusion of other factors are still being developed.
Hospice Visits When Death Is Imminent

CMS is creating measures to analyze how often skilled services received in the week prior to death. This measure is still being developed, and CMS has indicated that they will work with providers to develop the measurements.
Hospice Compare Star Rating System
Coming in the spring/summer of 2017
The Affordable Care Act (ACA) requires that reporting be made public on a CMS website and providers have an opportunity to review their data prior to public reporting. 
The infrastructure for public reporting is still under development. However, providers will have the "sufficient time" to review their data and make corrections and review again prior to it being shared with the public.
It is anticipated that providers will use these quality reports as part of their quality assessment and performance improvement (QAPI) efforts.
Medicare Care Choices Model (MCCM)

This five-year model would offer a new option for Medicare beneficiaries with certain advanced diseases who meet the model's other eligibility criteria to receive hospice-like support services from MCCM participating hospices while receiving care from other Medicare providers for their terminal illness.
Currently, the program is limited to dual eligibles with specific advanced diseases. The first cohort began under the model in January 2016.
Comment Due Date
Comments are due to CMS on June 20, 2016, no later than 5 pm EDT.
Read the complete rule
We will be reaching back out to membership for feedback and to offer a complete analysis of the proposed rule. Prior to this, if you have questions or concerns, please contact Vice President of Policy and Innovation Joy Cameron at or 571-527-1536.
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