Comments from Provider Needed to Protect Rates!

To: NHPCO Membership
From: NHPCO Regulatory Team
Re: June 16, 2009

The rates for hospice will be cut by 3.2% in October, and an additional 1% the following year unless CMS halts its plans to phase out the Budget Neutrality Adjustment Factor (BNAF) in the hospice wage index. Have you done everything you can to tell CMS to eliminate this rate reduction? Did you know that CMS has received NO comments from providers so far on this proposed rule? Regulators could take this lack of response from the hospice community as an indication that rate cuts will not present any problems for providers.

Act now…. Time is short...Comments are due next Monday, June 22...Tell your story about how the rate cut is affecting you and your hospice program. Here’s how...

How You Can Help
Key Issue and Talking Points: FY2010 Proposed Hospice Wage Index
Sample Letter

How You Can Help

Review the talking points below and submit your comments on the proposed rule to CMS. When preparing comments, please refer to file code CMS-1420-P. Comments must be received no later than 5:00 pm on Monday, June 22, 2009.


Electronic Comments:
The fastest and easiest way to submit comments would be electronically; visit http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=0900006480968c04 and follow the instructions to comment. Make sure you reference the document number: CMS-1420-P.


Written Comments:
You may mail written comments to the following address ONLY. Please allow sufficient time to ensure that mailed comments are received before the close of the comment period.

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–1420–P
P.O. Box 8012
Baltimore, MD 21244–8012

Express Mail:
You may send written comments (one original and two copies) to the following address ONLY.

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–1420–P
Mail Stop C4–26–05
7500 Security Boulevard
Baltimore, MD 21244–1850

Key Issue and Talking Points

Issue: FY2010 Proposed Hospice Wage Index

CMS proposes to continue its phase-out of the BNAF over the next two years, with a 75% reduction in FY 2010 and a complete phase-out in FY 2011.

Member Talking Points:

1. A 75% reduction in the BNAF is equal to a rate reduction of 3.2 % in FY2010, beginning October 1, 2009, and an additional one percent reduction in FY 2011, ultimately resulting in a rate reduction of approximately 4.2% for most hospices.
   Describe any direct impact the proposed rate cut will have on:
   - Patient and family services, such as: (services cut back, services discontinued, etc.)
   - Reductions in service area;
   - Employee layoffs;
   - Higher case loads;
   - Any other negative impact on program services because of the reimbursement cuts.
   
2. In a time of economic uncertainty and loss, with escalating costs (gas prices are on the rise again), a rate cut is exactly the wrong action for CMS to take.
   
3. CMS ought to encourage more patients and families to elect hospice care so that they will receive the care they need and deserve, and save the Medicare system money.

NHPCO will submit comprehensive comments but that is not enough. It is imperative that Regulators hear from members of the hospice community. It is especially important that you explain the impact these rate cuts will have on staffing and patient services.Thank you for your ongoing efforts to protect hospice!

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Note: NHPCO Regulatory Team issued a comprehensive Alert and Call to Action on June 9 that goes into more detail and looks at some of the broader issues. That alert is available on the NHPCO Web site.

For more information visit, http://www.nhpco.org