A new frontier, and I’m not afraid to stay curious

If Hamlet were a 21st century hospice leader, he might very well ponder the question, “To be (carved-in) or not to be (carved-in)?”  Will the Medicare hospice benefit be carved into Medicare Advantage Plans or not?  We have been discussing the implications of this since March 2014 when I was a CMS staffer and MedPAC discussed the possibility of ending the Medicare Advantage carve-out.  Since then, I’ve left the federal government, but  I am more curious than ever about whether Congress will act on MedPAC’s recommendation.

In the past, MedPAC recommended that Congress include the Medicare hospice benefit as part of Medicare Advantage plans’ scope of services.  MedPAC’s recommendation anticipates that MA plans take on the financial responsibility associated with offering patients high-quality hospice and palliative care services they need as a part of the full continuum of care – under the assumption that this will promote coordination of care resulting in lower Medicare spending.

There was and continues to be vocal protest from many stakeholders including the hospice provider community as well as the managed care plan community against MedPAC’s recommendation, which has likely prevented any action toward implementation. Our members at NHPCO have shared their concerns regarding the possibilities of reduced beneficiary access; reduced quality of hospices services; impact on the interdisciplinary care plan; and financial sustainability.  Some of the concern is based on the hospice experience with state managed care plans which has neither resulted in improved care coordination nor financial stability for hospices.

I do not consider their concerns trivial and I believe we need a deeper dive into the policy goals, technical complexities, and implications for the patient and caregivers.  An article from a March 2018 HealthAffairs blog helps put some of this into context.  Whether the hospice MA carve-in would help hospice providers and end-of-life care is still up for debate.

I am encouraged to see that CMS includes a new policy interpretation of what is considered “primarily health related” in its Calendar Year 2019 Call Letter.  Furthermore, Section 50322 of the Bipartisan Budget Act of 2018 requires the Government Accountability Organization to study the expanded supplemental benefits for the chronically ill, due to publish in 2023.  Both, the legislation and CMS policy, mark a new vision of the changing health care environment to one that recognizes the person-centered care model.

Hospices are uniquely poised in communities across the country to transform a health care industry from a medical model to a compassionate holistic care that accounts for the psychosocial and emotional needs of patients and caregivers.

This fall, NHPCO will partner with Better Medicare Alliance to take an unprecedented step by jointly holding a convening with key stakeholders to discuss the issues MA plans and hospices may face if hospice is included in Medicare Advantage plans.  It’s imperative that we fully engage in thoughtful discussion on this complex issue and remain curious together. 

By Zinnia Harrison, MHS
Vice President, Innovation & Inclusion
NHPCO

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NOTE: NHPCO is working to gather input from its hospice and palliative care membership regarding the MA carve-in and challenges and opportunities for the provider community.  NHPCO members may attend a free Virtual Town Hall on Thursday, October 4 at 2:00pm EST. Registration is required.