NHPCO Meets with CMS Administrator Seema Verma

Written by Judi Lund Person, Vice President, Regulatory and Compliance

On Wednesday, December 13, NHPCO’s President and CEO Edo Banach and I attended a productive meeting with CMS Administrator Seema Verma. Hospice Action Network board members Mark Murray, a hospice provider in South Bend, Indiana in Seema Verma’s home state, and Angie Sells, from AseraCare, a multi-state hospice provider attended the meeting as well and eloquently represented the hospice provider voice. The planned agenda for our meeting with Administrator Verma included a quick review on facts about hospice, our response to the Centers for Medicare and Medicaid Innovation (CMMI) request for information and progress on the Medicare Care Choices Model (MCCM), the impact on hospice when Medicaid managed care is in place, and concerns related to  Hospice Compare.

Pictured at the NHPCO office pre-meeting are NHPCO Vice President of Regulatory and Compliance Judi Lund Person, AseraCare President Angie Sells, NHPCO President & CEO Edo Banach, and Center for Hospice Care President & CEO Mark Murray.

On Wednesday afternoon, we made our way to the Hubert Humphrey building in downtown DC to meet with Administrator Verma.  She was joined by five members of the CMS staff, representing both the Center for Medicare and the Center for Medicare and Medicaid Innovation.  We began with a few quick data facts about hospice but quickly moved to a robust discussion about innovation, where we shared why the hospice and palliative care patient-centered approach is exactly in line with the Administrator’s goals for patient-centered care.  Verma was particularly interested in how hospices can be involved with patients earlier in their disease process, and we discussed the need for care navigation and coordination and how hospices are already involved in that process.

The meeting with Administrator Verma (center) was productive and informative.

We also had a discussion about the MCCM and talked about some of the limitations of the model, as well as what the learning has been.  We commented that the supportive services offered in the MCCM model are exactly what many patients need before they elect hospice.  Our hope is to build on that learning as we consider additional models.     

It was clear from our discussions that innovation is a high priority issue for the Administrator.  Our visit highlighted the skills and experiences of hospice providers to participate in models for seriously ill patients and develop new models to ensure that patients and their families have the care and supportive services they need.  We agreed to continue our discussions with Administrator Verma and CMS staff at the meeting. It was a productive and useful meeting, and we look forward to continuing to build upon the strong working relationship between NHPCO and CMS. 

NHPCO Draws Providers’ Attention to Article in New York Times

NHPCO members may have seen the article from Kaiser Health News that was posted on the New York Times website yesterday and appears in print in the Health & Science section today, "Concerns about costs rise with hospices' use."

NHPCO wanted to let members know that President/CEO Don Schumacher wrote a letter to the editor reminding the NY Times that growth in hospice over the past decade reflects our caring more compassionately for the dying in this country. He also made the point that NHPCO has been calling for more federal oversight of hospice for many years.

The NY Times blog page, New Old Age, welcomes comments from readers. Please feel free to share any thoughts you might have through the comment section of the New Old Age blog. An insightful comment was posted on the New Old Age blog that NHPCO would like to draw provider's attention to. An individual wrote: "I'm so thankful that this article was published, because we weren't aware that hospice care was available for end stage Alzheimers. We want to do everything we can to honor my mother's wish that she die in her own home, but if things become impossible,,,well it gives me great comfort to know there is another option."

To many of us, so close to issues that involve the field, it can be easy to forget that many members of the public are concerned about issues as they affect them in a personal way. Even challenging news articles can provide valuable information about hospice that is important to the public.

In addition to Don's letter to the editor, we are submitting an op-ed to the NY Times that we hope will get serious consideration.

Additionally, the Public Policy team has put together some specific talking points they are sharing with legislators and their staffs on Capitol Hill who may have concern or confusion resulting from this article.

We wanted to assure members that NHPCO has been actively responding following the release of this article.

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Dartmouth Atlas Report

US End-of-Life Care Changing: While Medicare Patients are Spending Less Time in Hospital, Those Admitted Receive More Intensive Care

Chronically ill Medicare patients spent fewer days in the hospital and received more hospice care in 2007 than they did in 2003, but at the same time there was an increase in the intensity of care for patients who were hospitalized, according to the Dartmouth Atlas Project report "Trends and Variation in End-of-Life Care for Medicare Beneficiaries with Severe Chronic Illness."

"It may be possible to reduce spending, while also improving the quality of care, by ensuring that patient preferences are more closely followed," said David C. Goodman, M.D., M.S., lead author and co-principal investigator.

Download the full report in PDF from Dartmouth Atlas website.

Hospice Community Disappointed in Administration’s Decision and Reminds All Americans of the Value of Advance Care Planning

(Alexandria, Va) – “We are surprised that the Administration has decided to reverse the decision to include voluntary advance care planning consultations as part of a Medicare beneficiaries’ annual wellness exam,” remarked J. Donald Schumacher, president and CEO of the National Hospice and Palliative Care Organization.

Despite this action, NHPCO strongly encourages all Americans to think about their wishes for care at the end of life and engage in advance care planning. This includes having discussions with healthcare providers and family members, completing an advance directive (which includes a living will and healthcare proxy), and making sure their loved ones understand their wishes.

“Frankly, we are somewhat disappointed that the regulatory guideline making this part of the annual Medicare exam and compensating the physician for taking time to talk about personal preferences has become such a political issue,” continued Schumacher. “It's simply about educating patients about the types of decisions they might need to consider in future healthcare situations, and then supporting them as they make their own choices based on their values, beliefs and preferences.”

The opportunity for this voluntary consultation with a physician has been part of the “welcome to Medicare” exam since 2008.

Research has shown that patients who discuss their care options when facing a serious or life-limiting illness report a higher quality of life, less hospitalizations and fewer visits to the emergency department. Family caregivers have also been shown to benefit from discussions held between physicians and patients.

Far too often, patients and their families are forced to make decisions in times of crisis; these voluntary advance care planning consultations would have facilitated informed conversations prior to the onset of an illness or medical crisis.

“Death and dying can be a difficult topic for people to deal with – this includes politicians crafting legislation, healthcare providers caring for patients, and people who may be confronting a serious illness. But as hard as this can be, it’s far more difficult for a patient and family to face a medical crisis without a prior understanding of an individual’s wishes and how quality of life might be addressed. Knowing a loved one has engaged in discussions with a knowledgeable physician can bring comfort to patients and families—and that can be quite a gift at a challenging time,” Schumacher said. “Having this option spelled out in Medicare regulations would have raised awareness of advance care planning and potentially opened the door for valuable conversations.”

NHPCO emphasizes that advance care planning is not about discontinuing treatment, saving money, or having someone else make decisions for you; it’s about making sure your wishes are known and then honored, regardless of whether you choose every medical intervention available, discontinue non-productive treatments, or something in between.

There is concern among hospice providers that the debate about this regulation and last year’s “death panel” rumors will cause additional confusion to members of the public and make them even more suspicious of advance care planning.

Hospice and palliative care providers are skilled in helping people understand issues of importance when facing a serious or life-limiting illness and can be important resources for those looking to learn more or make their wishes known.

NHPCO’s Caring Connections offers information on care at the end of life and provides free, state-specific living will and healthcare proxy forms: Visit www.caringinfo.org or call the HelpLine at 1-800-658-8898.

Dartmouth Atlas Report Identifies Gap between Patient Wishes and Care Received

NHPCO Commends Dartmouth Atlas Project and Calls on Hospitals to Increase Access to Hospice Care

(Alexandria, Va) – A new report released today from the Dartmouth Atlas Project showing that individuals in some areas of the country are far less likely to receive comfort care in accordance with their wishes and has drawn the attention of the nation’s hospice and palliative care community.

This first-ever report from the Dartmouth Atlas Project on cancer care at the end of life, found that across the US, about 29 percent of patients with advanced cancer died in a hospital between 2003 and 2007. And in 50 academic medical centers, fewer than half of these patients received hospice care.

Furthermore, the study authors state that many patients are aggressively treated with curative therapies they may not want, and, “for frail elderly patients, and any patient with advanced cancer, these treatments have limited or no benefit.”

“The Dartmouth Atlas Project is to be commended for undertaking this thorough examination of end-of-life care for Medicare beneficiaries with advance cancer,” said J. Donald Schumacher, president and CEO of the National Hospice and Palliative Care Organization. “While the findings of variation in care are not necessarily a surprise, one of the key messages that I take away from this report is the critical need for hospitals and all healthcare professionals to ensure that all patients are informed earlier about the course of an illness and the range of options available – options that include hospice and palliative care.”

The likelihood that a Medicare patient with advanced cancer will die with the support of hospice care, or in the hospital without hospice, varies markedly depending on where he or she lives and receives care. The percent of cancer patients dying in a hospital varied threefold among patients receiving most of their care at academic medical centers.

“It’s important to recognize that this report is not a negative comment on care in our nation’s hospitals or among academic medical centers, rather, it’s a much needed reminder that healthcare professionals must work to help patients and families understand where the course of their illness may take them. And, when cure is not possible, it is our duty to offer the robust benefits that the hospice team can provide,” added Schumacher.

Hospice care provides coordinated care delivered by a team of interdisciplinary professionals that are trained to address the special needs a person has at the end of life. The hospice team provides pain and symptom relief as well as emotional and spiritual support for the patient and the family.

More than 1.56 million Americans received care from the nation’s hospices last year. However, 34 percent of patients died or were discharged in seven days or less – too short a time to take full advantage of all of the services available under hospice, including support for family caregivers.

“In more than 30 years of running hospice programs, the most frequent comment I would hear from patients and families was why they didn’t learn about hospice care earlier,” Schumacher noted.

For several years, NHPCO’s Caring Connections has been providing healthcare professionals and consumers with information about care options and caregiving when facing serious or life-limiting illness. Information to help patients and family caregivers understand the benefits of hospice care, speak with physicians about care, or learn about advance care planning is available free of charge from NHPCO’s Caring Connections at www.CaringInfo.org or by calling the HelpLine at 1-800-658-8898.

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The Dartmouth Atlas Project is run by the Dartmouth Institute for Health Policy and Clinical Practice and principally funded by the Robert Wood Johnson Foundation. A link to the full study can be found at www.dartmouthatlas.org.

NHPCO is the oldest and largest nonprofit membership organization representing hospice and palliative care programs and professionals in the United States. NHPCO’s mission is to lead and mobilize social change for improved care at the end of life, www.nhpco.org.

Contact:
Jon Radulovic
NHPCO, Vice President of Communications
Ph: 703-837-3139
jradulovic@nhpco.org

Researchers Find that Cancer Patients who Disenroll from Hospice have Increased Hospitalizations and are less likely to Die at Home

Disenrollment can have a Physical and Financial Toll

(Alexandria, Va) – According to a new study, patients with terminal cancer that disenrolled from hospice care had significantly higher rates of hospitalizations – including admission to the emergency department and intensive care unit – than patients who remained under the care of hospice. Furthermore, patients who disenrolled from hospice were more likely to die in the hospital than patients who remained with hospice until their deaths.

National Hospice and Palliative Care Organization hopes that healthcare professionals and policy makers will take time to look at this and other recent studies that help provide a better understanding of both the cost and quality-of-life benefits associated with the hospice experience, including honoring a patient’s wish to be able to die at home.

The study, which was led by researchers at the Mount Sinai School of Medicine, found that:

• 33.9 percent of the patients who disenrolled from hospice care were admitted to an emergency department, in contrast with only 3.1 percent of hospice patients.
• 39.8 percent of disenrolled patients were admitted to the hospital as an inpatient, in contrast with only 1.6 percent of hospice patients.
• Disenrolled patients spent an average of 19.3 days in the hospital, whereas hospice patients spent an average of 6.7 days.
• 9.6 percent of disenrolled patients died in the hospital, compared to only 0.2 percent of hospice patients.
• Costs of care for patients with cancer who disenrolled from hospice were nearly five times higher than for patients who remained with hospice.

“Impact of Hospice Disenrollment on Healthcare Use and Medical Expenditures for Patients with Cancer” is published in the October 1, 2010 issue of Journal of Clinical Oncology.

“This study illustrates the tangible value of hospice care to patients who want to die at home, with the support of the hospice interdisciplinary team, surrounded by family rather than in a hospital connected to machines. There are significant emotional and financial benefits to the patient, family and healthcare system when hospices are caring for people,” said J. Donald Schumacher, NHPCO president and CEO. “In my 30 years running a hospice, I heard time and time again from families that wanted to keep their dying loved one at home.”

“There are numerous reasons why a patient may disenroll from hospice, and while those factors were not part of this study, we are reminded of the importance of advising patients and families as to the potential toll that might accompany leaving hospice care prematurely. A toll that may be physical, emotional, and financial,” added Schumacher.

Wrote the study authors, “Policy makers have called for tightening eligibility restrictions for the MHB (Medicare Hospice Benefit) as part of a wider effort to reduce high Medicare expenditures; our results suggest that addressing hospice disenrollment may be an effective means of reducing Medicare expenditures for hospice users without restriction access to the MHB.”

Further recommendations suggest that oncologists explore outpatient palliative care services that offer multidisciplinary care, symptom control, and end-of-life planning expertise in a context that enables a patient and family to maintain contact with the oncology clinic.

In his plenary address at NHPCO’s “Developing the Continuum of Care” conference held in Boston on August 5, Dr. Schumacher encouraged all hospice providers to explore ways that they can offer “pre-hospice” palliative care services in their communities and work with other providers to ensure patients and families have the right care at the right time from diagnosis on through bereavement for family.

More than 1.5 million patients with life-limiting illness receive care every year from the nation’s hospices.

Information about hospice and advance care planning is available from NHPCO’s Caring Connections. Visit caringinfo.org or call the HelpLine at 1-800-658-8898.

Promising Steps

I am heading to our conference on “Developing the Care Continuum” next week and I’m looking forward to what I know will be some thoughtful, forward-thinking discussions. Devoting an entire event to exploring the various ways we can become more visible, more available, and more valuable to the people in our communities is, in itself, a forward-thinking strategy—and also very timely.

Greater attention will be placed on improving care coordination and eliminating duplicative services as the health reform law is implemented over the next several years. All hospices, not just a select few, need to begin thinking, planning, and taking steps toward greater collaboration or the diversification of their services if they want to grow their census. Palliative care is certainly one option that is already on the rise in hospitals. However, other services are also helping hospices to establish relationships with patients and other providers earlier in the life cycle. In the coming weeks, NHPCO will make available both webcasts and session tapes from the conference to help members who were unable to attend.

Be mindful, too, of the positive steps that are also being taken here in Washington (yes, Washington!):

• From our conversations with Senator Ron Wyden, we know the Concurrent Care Demonstration Project is now taking shape. This three-year project, which will be conducted by CMS, will monitor patients at 15 different hospice programs who will be permitted to receive other Medicare-covered services as well as hospice care. The goal is to evaluate the impact of concurrent care on the patient and family’s quality of life as well as the cost of care. It has the potential to strengthen the bridge between hospice and palliative care—and may be another good reason to consider a partnership or expansion into palliative care.
• Undaunted by the ‘death panel’ debacle of last summer, Representative Earl Blumenauer has also re-introduced legislation calling for Medicare and Medicaid to cover voluntary consultations about end-of-life care planning between patients and their physicians. NHPCO worked with the Congressman to help advance this valuable legislation, including a formal letter of support.

I know that running a hospice program today is not easy, given the regulatory and economic challenges of our times. As one colleague admitted, “it’s easy to get stuck in the weeds.” But it is far too critical a time to let that happen. This new decade holds much promise—if we are all poised and ready to be part of it.

Don

NHPCO & Alliance to Offer Health Care Reform Phone Forum Next Week

The negotiations, progress and temporary set-backs of health care reform continue, and the hospice community has never had more on the line. Will the BNAF rate cuts be addressed in the bill? Will Congress modernize the Medicare Hospice Benefit and expand access to hospice? Could access be hindered by the health overhaul? Will we suffer more cuts to help pay for reform?

Please join NHPCO President/CEO Donald Schumacher, Vice President of Public Policy Jonathan Keyserling, and members of the Alliance for Care at the End of Life lobbying team on Wednesday, July 29 at 3pm EDT for an update and responses to your questions on the timing, substance and process of what’s to come in health care reform.

Register for the Phone Forum Here

This unprecedented opportunity is being offered at no charge for NHPCO members; however, please be considerate of this generous offer by restricting your registrations to one phone line per hospice program.

Register for the Phone Forum Here

Important Information: Registration closes at noon (EDT) on Monday, July 27. Registrants will receive the call instructions on Tuesday, July 28. CEUs will not be offered for this event. Please send any questions to advocacy@nhpco.org.
We hope you will join this important discussion!

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

Monthly Message from NHPCO's President and CEO Don Schumacher

July 2009


Exploring Multiple Pathways to Earlier Referrals


Our cover story this month draws needed attention to the myths surrounding palliative care. Much like hospice, palliative care is not being fully utilized within our nation’s healthcare system due to sheer misunderstanding on the part of patients and physicians. As the author notes, there are nearly one million patients who are dying in hospitals or other institutions each year who are unaware of the palliative care services available to them—care that would not only help them, but would also reduce hospital and pharmacy costs.


While it’s certainly our collective responsibility to help educate our communities about palliative care, we are missing a very important opportunity if we don’t do more—if we don’t expand into palliative care ourselves. In one of my first conference plenary addresses as president/CEO of NHPCO, I urged members to “think outside the Medicare Hospice Benefit box” and explore palliative care as a pathway to earlier referrals. I was not asking members to do something I had not done myself. While president/CEO of a hospice program in Buffalo, I was one of the first providers to integrate palliative care into our continuum of care and saw firsthand the many benefits of such expansion.


Today, with healthcare reform very much a reality and with CMS now looking at ways to serve more Americans more cost effectively, there is even greater reason to expand our expertise into other cost-effective services. Palliative care is a natural fit for hospice providers.


Opportunities at the National Level


This month’s secondary feature recaps findings from NHPCO’s recent Economic Impact Survey. Understandably, most programs reported a reduction in revenue, with reasons ranging from reductions in average daily census to expected reductions in philanthropic contributions and changes in payment rates. First, on behalf of NHPCO, my thanks to all of you who took time to respond. Secondly, NHPCO hears you.


While NHPCO can’t address all of the factors that are impacting your bottom line, we are committing significant resources to the one that poses the greatest threat to the majority of members—Medicare Hospice Benefit rates. In partnership with The Alliance for Care at the End of Life, protecting these rates remains our top priority (see page 16 for an update on our advocacy efforts). However, we are also exploring other ways to improve your bottom line through expansion of the Benefit. NHPCO’s Public Policy Committee recently approved two potential demonstration projects to examine concurrent care and transitional care, both of which would enable hospice providers to build relationships with patients and families earlier in the illness trajectory and, in so doing, improve hospice utilization.


A favorite expression of mine reminds us that there are, indeed, many paths up a mountain. In today’s hospice environment, we must be open—and willing—to explore them all.

Don

Read July NewsLine

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

Letter to President Obama

Hospice Community Urges President Obama to Stop Funding Cuts

Cuts Beginning October 1 Will Reduce Access to Care for Dying Americans

(Alexandria, VA) – Today, 3,524 hospice providers from across the country sent a letter to President Barack Obama urging him to stop cuts to the Medicare hospice benefit beginning on October 1, 2009.

The cuts threaten to jeopardize availability of the compassionate and high-quality care that 1.5 million patients and their family caregivers receive from hospice providers each year.

In addition to the letter, more than 500 providers of the hospice community submitted comments to the Centers for Medicare and Medicaid Services (CMS) on how the cuts will cause them to decrease services, reduce staffing, and in some cases, close their programs.

This follows two Congressional letters sent to President Obama by 45 U.S. Senators and 171 U.S. Representatives, demonstrating that he has strong, bipartisan support to stop the cuts in hospice funding.

The cuts come from a 2008 federal rule that eliminates a component of the Medicare hospice benefit known as the budget neutrality adjustment factor (BNAF). Members of the hospice community have been calling and emailing the Administration requesting that implementation of this rule be stopped.

“The sheer number of hospice programs represented by this letter and those recently sent by Members of Congress should send a strong message to the White House about the urgency in stopping these cuts,” said J. Donald Schumacher, president and CEO of NHPCO.

Earlier this year, President Obama and Congress approved a moratorium on the hospice funding cuts that expires on September 30, 2009. Without further action, hospice reimbursements will drop by 3.1 percent, leaving hospice programs, particularly smaller and rural ones, facing cutbacks in services and possible closure.

Hospice is a proven Medicare cost saver. In 2007, an independent, Robert Wood Johnson Foundation-funded study by Duke University found that hospice reduced Medicare costs by $2,300 per patient, saving more than $2 billion per year.

Hospice is also considered to be the model of high-quality care at the end of life. Research from NHPCO shows that 98 percent of families served by hospice are willing to recommend its care and services to others.

For more information about NHPCO’s efforts to protect hospice funding, please visit NHPCO’s Advocacy Web page at: nhpco.org/advocacy.

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Contact:Angie Truesdale

Ph: 703-647-5163

atruesdale@nhpco.org

Jon Radulovic

Ph: 703-837-3139

jradulovic@nhpco.org

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

Costs of Care at EOL

Discussions About End-of-Life Care Reduce Healthcare Costs in Last Week of Life

NHPCO Encourages Dialog between Patients and Physicians

(Alexandria, Va) – Patients with advanced cancer who reported talking about their end-of-life wishes with their physicians had significantly lower healthcare costs in the last week of life. Researchers found that these conversations between patients and physicians led to fewer cases of aggressive care, which saved money and resulted in a far more peaceful death for patients.

The study in the March 9 issue of Archives of Internal Medicine suggests a tangible benefit to advance care planning discussions with physicians – lower costs and reduced utilization of aggressive care, including admission to the Intensive Care Unit.

Thirty percent of Medicare’s annual costs are spent on the five percent of beneficiaries who will die in a given year. Additionally, about one-third of those dollars spent in the last year of life are spent in the last month.

“Discussions about care at the end of life result in a higher quality of life for patients – and cost the healthcare system less money, that is something that hospice and palliative care providers have long known” said J. Donald Schumacher, president and CEO of National Hospice and Palliative Care Organization.

A 2007 study out of Duke University found hospice saves Medicare about $2,300 per beneficiary that receives hospice care.

Researchers in this recent survey looking at costs in the last week of life indicate that if 50 percent of people had a discussion with their physician about end-of-life care preferences, the cost difference in a year could be more than $76 million dollars.

Study participants who discussed end-of-life care preferences were more likely to be referred to hospice sooner than those who did not.

“In fact, patients who received less invasive or aggressive treatments lived as long as patients who did not, indicating that attempts to prolong life in end-stage cancer patients might be futile,” noted Schumacher.

Research published in the Journal of Pain and Symptom Management (March 2007) found that Medicare beneficiaries who opted for hospice care at the end of life lived on average 29 days longer than similar patients who did not take advantage of hospice.

NHPCO has been a longtime advocate for people having frank discussions about the care they would want – primarily to ensure that a person’s wishes are honored and that they experience the highest quality of life possible.

“An important time to talk to your doctor about the kind of care you would want at the end of your life is not when you’re days away from death but much earlier in the course of an illness,” said Schumacher.

“In fact, I cannot stress the importance of advance care planning for all people. Taking time, right now, to have these discussions with family and loved ones can be very important in making sure wishes are honored should a medical crisis come along,” added Schumacher.

Last year, more than 1.4 million Americans with life-limiting illness received the quality care from the nation’s 4,700 hospice care providers.

Information on care at the end of life, starting these important conversations with loved ones and care providers, and state specific advance directive forms, are all available free-of-charge on NHPCO’s Caring Connections Web site, www.caringinfo.org, or from the Helpline at 800-658-8898.

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

NHPCO Statement on MedPAC Recommentdations to Congress

(Alexandria, VA) – Today, the National Hospice and Palliative Care Organization released the following statement upon the release of the Medicare Payment Advisory Commission’s (MedPAC) March report to Congress. The report includes recommendations to revise the Medicare hospice benefit.

Each year, more than 1.4 million patients and family caregivers seek hospice care. The Medicare hospice benefit is responsible for millions of people living as fully as possible until the end of life. The hospice community is dedicated to not only preserving the benefit, but enhancing it so that hospice is able to continue to appropriately serve the unique and changing needs of dying Americans. Hospice and palliative care providers, through the support that comes from Medicare, are recognized as the leading providers of the interdisciplinary, holistic care considered to be the “gold standard” of end-of-life care.

Hospice care is also cost-effective. As was reported in a 2007 Duke University study, hospice reduced Medicare costs by an average of $2,300 per patient, amounting to a $2 billion savings in a single year.

Statement on MedPAC’s Recommendations for Hospice Reform:

Over the past several years, MedPAC has undertaken a review of the Medicare hospice benefit. While specific reforms and enhanced accountability measures are laudable and should be encouraged, those changes should be framed in the context of a comprehensive review of the various and complex components of end-of-life care, and how the continuum of care can be expanded to increase access for patients and families. Included in this comprehensive review of hospice should be payment methodologies, fiscal constraints review, alternative eligibility criteria, testing of new models of care, as well as any number of other issues. The hospice community is committed to work toward these goals.

Guiding this review ought to be several clear principles. Among them are:

• Advancing hospice and palliative care programs as the recognized providers of end-of-life care;
• Preserving and enhancing the Medicare hospice benefit;
• Recognizing “high quality” as the standard to which all providers must subscribe;
• Ensuring accountability through transparency and fair regulatory scrutiny; and
• Promoting increased access through expansion and collaboration.

Payment policy is one of the areas of the Medicare hospice benefit that needs to stay current, so that payment appropriately recognizes changes on patient demographics and treatment protocols. Updates should be carefully considered and evidence-based to ensure that behavioral consequences are understood prior to implementation. The present payment methodology has served the hospice community and the public well since its inception, virtually without change. Analysis of both current and historical patient level data is necessary to fully understand and predict future behavior and needs, and make changes that continue to provide benefits to patients and to the Medicare system.

As with any payment system, dramatic changes to the hospice benefit from established patterns of reimbursement are sure to produce displacements and unintended negative consequences. Given the nature of hospice referrals and the unique characteristics of the end-of-life patient demographics, unintended consequences of such changes are inherently difficult to predict. Any number of issues might warrant attention, but effectively quantifying such items in terms of behavior changes of patients and providers would be difficult. Payment reforms should be incremental, based on adequate data analysis, and need to be undertaken carefully, with effects on the patient and family in mind.

The hospice community applauds the open and informed process that MedPAC undertook to produce the recommendations, and looks forward to working with the Commission, appropriate oversight agencies, and Congress to ensure that the Medicare hospice benefit continues to serve patients at the end of life in the compassionate and high-quality manner that they deserve and expect.”

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Contact:Sara Perkins
Manager, Public Policy Communications
Ph: 703-837-3135
sperkins@nhpco.org
For more information visit, http://www.nhpco.org