CMS published their proposed Hospice Payment Rate updates on April 14. The proposed rule has changes beyond the payment rate that will impact hospice. The changes include:
- Hospice Conditions of Participation (CoPs)
- Hospice Quality Reporting Program (HQRP)
- Home Health Quality Reporting Program (HH QRP)
- Routine updates to hospice base payments and aggregate cap amount for FY 2022
- Rebase the hospice labor shares
- Update and clarify the hospice election statement addendum requirements
Hospice Conditions of Participation (CoPs)
This proposed rule updates CoPs regarding hospice aide competency evaluation standards. Part of the COVID-19 PHE was waving the hospice aide competency testing to allow for the use of pseudo-patients. CMS is proposing this PHE waiver be made permanent and is proposing the use of pseudo-patients for the hospice aide competency training.
Hospice Quality Reporting Program (HQRP)
There are two new measures being proposed by CMS in the HQRP called the Hospice Care Index and the Hospice Visits in the Last Days of Life (HVLDL) for public reporting. The Hospital Care Index measure includes 10 indicators of quality that would be calculated from claims data. The purpose of the measure is to measure the comprehensive quality of care furnished by hospice. If finalized, the measure would be reported no earlier than May 2022. The claims-based Hospice Visits in the Last Days of Life (HVLDL) measure is intended to inform caregivers of hospice performance.
CMS is proposing removing the seven individual Hospice Item Set (HIS) measures because the Hospice Comprehensive Assessment Measure (NQF#3235) is similar and already publicly reported.
CMS is also announcing an update on the Hospice Outcome and Patient Evaluation (HOPE) assessment instrument.
Home Health Quality Reporting Program (HH QRP)
To meet January 2022 public reporting refresh cycle for Home Health Facilities, CMS is including a HH QRP proposal for the FY 2022. They propose using three quarters rather than four quarters of data for January 2022 refresh that affects OASIS-based measures. For some other claim-based measures, CMS is proposing using three quarters rather than four for refreshes between January 2022 and July 2024.
Routine Updates to Hospice Base Payments and Aggregate Cap Amount for FY 2022
Hospices are proposed to receive a 2.3 percent increase in their payments for FY 2022. Hospices that fail to meet quality reporting requirements will receive a 2 percent reduction to the annual market basket for FY 2022.
Hospice payment update includes the aggregate cap that limits the overall payments per patient that is made to hospice annually. The proposed cap amount for FY 2022 is $31,389.66.
Rebase the Hospice Labor Shares
Update and Clarify the Hospice Election Statement Addendum Requirements
Nine textual changes and clarifications have been proposed to the Hospice Election Statement Addendum
The proposed rule also includes Return for Comment (RFI) for the following areas:
CMS is seeking comments from the public on hospice utilization and spending patterns. Through the data provided in the proposed rule, CMS is hoping to further develop policies that will see better utilization of hospice services.
Fast Healthcare Interoperability Resources (FHIR)
Over the last several years, it has become apparent that CMS’s mission of promoting interoperability, improving data reporting, and enhancing patient outcomes through data sharing is an important mission. The 21st Century Cures Act requires Health IT Developers of Certified Health IT must be interoperable and must eventually be able to share data using the HL7 FHIR format. In this proposed rule, CMS is seeking information to integrate digital quality measurement via FHIR.
Health Equity Gap in the Hospice QRP
Based on Executive on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, CMS is inquiring on best practices for ways to bridge health equity for underserved communities via the HQRP and other quality reporting initiatives.
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