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. 

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

FY2011 Wage Index and Tools for NHPCO Members Now Available

CMS has posted the FY2011 hospice rates and aggregate cap. NHPCO offers members two important tools.

1) FY2011 Excel spreadsheet with the FY2011 wage index and the FY2011 rates for each county in each state.
2) FY2011 rate calculator that projects the wage index values and rates through FY2019. The calculator also allows you to project a percentage growth in your hospice's census for each year.

Links to these tools are available on the Wage Index page of NHPCO's website. Here's a link to the Regulatory Alert that went out to members on July 26, 2010.

Additionally, the PDF of CR7077 is available on the CMS website.

The Moran Data Project: Is your hospice participating?

The participation of all hospice providers across the country is needed for a very important project that has the potential to impact every provider in the U.S. I'm writing about the Moran Data Project.

For those not familiar with the project, last July, NHPCO retained The Moran Company (a healthcare research and consulting firm specializing in payment reform) to conduct our own data collection and assessment project on behalf of the hospice and palliative care field. This is in response to impending work on hospice reimbursement reform that is now required as a part of the new health care reform law and requires CMS to initiate hospice payment reform no earlier than 2014.

I would like to share the video message linked below:




For those unable to access the video, here is some additional information about the Moran Project.

The Moran Data Project

Through data collected and analyzed in the Moran Data Project, NHPCO will develop and present to CMS and MedPAC alternative Medicare hospice payment reform models that fairly reimburse us for the care we provide. This proactive approach allows us to exert some influence on the process rather than relying solely on government regulators and the data they can access. However, in order for our models to be sound, we must have comprehensive, patient-level data—and for that, we need the assistance of all hospice providers.

The data collection phase of this project began in February and there are now about 200 providers which are submitting data—but we need 800 more providers of all sizes, type and from all areas of the country to step up and contribute data.

By coming together to present to MedPAC and Congress comprehensive data from a unified hospice industry, we can help preserve our core values and our revenue streams. NHPCO will fight for this—but we can't do it alone. Working together to collect data, we can make our voices heard. Members can learn more online at nhpco.org/moran or contact Amanda Forys at The Moran Company at aaforys@themorancompany.com.

Thank you for your participation!

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NHPCO would like to thank the software vendors who are participating in this important data collection project:

• Allscripts
• Cerner BeyondNow
• Consolo Services Group
• Delta Health Technologies
• Homecare Homebase
• McKesson Corporation
• HPMS - Mills & Murphy Software Systems, Inc.
• mumms® Software
• Suncoast Solutions

Don's 2010 May Update

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

A Closer Look at the Health Care Reform Provisions Impacting Hospice

Earlier this week, NHPCO's Public Policy/Advocacy Team sent you an important update on the passage of the health reform legislation and next steps for the hospice community. NHPCO wants to share what we know about the various provisions impacting the hospice community. In some cases, you will see that there is not yet much information. Many of the provisions will be implemented by the Health and Human Services Secretary, and administered through the Centers for Medicare & Medicaid Services (CMS). But, in order to do that, we believe that the first order of business for the Administration will be to appoint a CMS Administrator to delve into the details of implementation and oversight.

Visit NHPCO's Advocacy page for more information on the provisions that will be significant to hospice.

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

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