FY2019 Hospice Wage Index Proposed Rule

On Friday, April 27, 2018 CMS posted the FY2019 Hospice Wage Index Proposed Rule. Staff at NHPCO analyzed the proposed rule and published a Regulatory Alert on April 30, 2018 that provided more detailed information for the membership. Some highlights of the proposed rule include:

• Hospice rates will increase by 1.8% for FY2019.  The cap amount has also increased by the same percentage to $29,205.44.  
• Physician assistants will be able to serve as a hospice patient’s attending physician, effective January 1, 2019. NHPCO has worked in collaboration with the American Academy of Physician Assistants for their inclusion in the statute. Hospice patients will have additional choices for their attending physician once this provision is effective. 
• CMS has reduced regulatory burden for hospice providers by allowing drugs and durable medical equipment to be reported in the aggregate on the claim form, rather than the extremely burdensome per drug or per equipment reporting that currently exists. CMS estimates that the elimination of this burdensome reporting will reduce the number of line items reported on claims by 21.5 million, in the aggregate.   
• There will be no new hospice quality measures in FY2019. 
• Data points from the hospice public information, currently available in the Provider Use File and posted by CMS, will be added to an “information” section in Hospice Compare, so that Medicare beneficiaries and their families have information that will assist them in selecting a hospice that meets their needs. 

CMS published a data trend analysis of hospice claims and cost report. Concerns continue to be raised about the number of patients who did not receive a skilled visit in the last seven days of life, the number of drugs paid for by Part D after the patient has elected hospice, and the lack of completeness in the hospice cost report. It's essential that hospice providers be aware that there is likely to be increased focus on these areas in the future.

Comments on the proposed rule are due to CMS no later than June 26, 2018. NHPCO submits a comment letter and encourages all providers with feedback to share that with CMS.

NHPCO members will find more detailed analysis in its Regulatory Alert (04/30/18).