Comments on CMS Proposed Payment FY2014 Update for Hospice

On Monday, April 29, The Centers for Medicare and Medicaid Services released a proposed rule which would update the fiscal year (FY) 2014 hospice reimbursement rates.  The CMS notice claimed that hospices would receive a 1.1 percent market basket increase in their reimbursement.

NHPCO's official comment letter to CMS will be submitted as instructed; however, J. Donald Schumacher, president and CEO of the National Hospice and Palliative Care Organization offers the following public comments on the proposed rule.

Beyond the policy considerations, the numbers just do not add up. For CMS to characterize hospices as receiving a positive update, much less an $180 million dollar increase, without factoring in the impact of the sequester is disingenuous.  The truth is, under current law, CMS’ proposed payment update would mean a -.9 percent decrease for the nation’s hospice community.

Hospices are already struggling with an increased regulatory burden and productivity cuts associated with PPACA.  For the hospice community, which has a high proportion of Medicare/Medicaid patients (almost 90 percent) and an average margin of 4.6 percent – without even taking into account the impact of sequestration – any proposed negative update could be catastrophic.

This is a time when access to hospice should be encouraged, not threatened.  Virtually every responsible policy maker acknowledges that more end of life care patients should have access to the high quality and compassionate services offered by the nation’s hospice programs.  

New research out of Mount Sinai’s Icahn School of Medicine, published in the March 2013 issue of Health Affairs, (affirming previous cost saving research from Duke University) found that hospice enrollment saves money for Medicare and improves quality from Medicare beneficiaries by reducing emergency room stays, ICU days and hospital readmissions.  And yet, we’re already seeing layoffs and consolidation in the hospice community.  The proposed negative update sends a message to the hospice community to expect more of this disturbing trend.

J. Donald Schumacher, PsyD
President and CEO
National Hospice and Palliative Care Organization