President Obama Signs IMPACT Act Bringing Valuable Oversight to Hospices

Yesterday afternoon, President Obama signed into law the “Improving Medicare Post-Acute Care Transformation Act of 2014” (IMPACT Act) that includes provisions creating greater oversight and increased transparency within the hospice community. The National Hospice and Palliative Care Organization heralds the passage of this legislation and the additional oversight it will bring to end-of-life care providers.

The provisions that affect hospice providers are:

1. Mandated surveys of Medicare certified hospice providers at least every three years for the next ten years at the minimum.
2. Medical reviews for hospice programs with a soon to be determined percentage/number of patients receiving care for more than 180 days. The specific patient load that would trigger this medical review will be set by CMS.
3. Hospice aggregate financial cap will be aligned with hospice reimbursement using a common inflationary index that will not change hospice reimbursement for providers.

“As hospice and palliative care providers, we care for patients and families at one of life’s most vulnerable times.  Americans need to know that all Medicare-certified providers are committed to the highest standards of quality and compliance.  This new law strengthens oversight and transparency throughout the entire hospice community,” said J. Donald Schumacher, NHPCO president and CEO. “NHPCO applauds President Obama for signing the IMPACT Act into law.”

“Under NHPCO’s leadership, the hospice community has been on the frontlines of advocating for increased transparency, program integrity, and accountability. We believe that the hospice provisions included in the IMPACT Act are critically important steps in this direction,” stressed Schumacher.

CMS Invalid Hospice Diagnosis Codes

Hospice providers should be aware of the list of “Invalid Hospice Diagnosis Codes” which should not be used as a primary diagnosis for a hospice patient for dates of service beginning October 1, 2014 or later.

The Centers for Medicare and Medicaid Services issued CR 8877, "Hospice Manual Update for Diagnosis Reporting and Filing Hospice Notice of Election (NOE) and Termination or Revocation of Election" on August 22, 2014.  At that time NHPCO advised the field and created a compliance update document in late August with the details of all provisions of CR 8877.

Recently, the Regulatory Team at NHPCO has received numerous questions about the invalid diagnosis codes contained in Attachment A of this CMS Change Request.  Of particular importance are coding guidelines related to:

• ICD-9-CM/ICD-10-CM Coding Guidelines
• ICD-9-CM/ICD-10-CM Dementia Coding Guidelines
• Hospice Invalid Principal Diagnosis Codes 

Providers should be familiar with the provisions of CR 8877, "Hospice Manual Update for Diagnosis Reporting and Filing Hospice Notice of Election (NOE) and Termination or Revocation of Election." This Change Request provides a manual update and provider education for CMS edits in place for principal diagnoses that are not appropriate for reporting on hospice claims.

NHPCO members looking for assistance with CR 8877 will find a Regulatory Alert (10/02/14) posted on the NHPCO website that includes a link to the original compliance update document released last August.

Naomi Judd to open national hospice palliative care conference in October

Naomi Judd will be the honored opening plenary speaker at NHPCO’s upcoming Clinical Team Conference in Nashville, Tennessee, October 27 – 29, 2014.

At the opening plenary presentation on October 27, the celebrated Naomi Judd will present, “Surviving and Thriving in Challenging Times” at the opening session of the National Hospice and Palliative Care Organizations 15^th annual Clinical Team Conference and Pediatric Intensive being held at the Gaylord Opryland Resort & Convention Center.

Naomi Judd knows a thing or two about surviving and thriving through challenges. Using her own touching personal stories and unique brand of humor, Naomi will share her journey of being both a patient (as a Hepatitis C survivor) and a caregiver (as a former nurse early in her life).

From humble beginnings as a single mom in a small Kentucky town to her meteoric rise as a country music superstar and American icon, Naomi Judd’s incredible lifelong journey is an inspiring story of overcoming the odds through optimism and hard work, first known to the world as half of country music’s mother/daughter duo, The Judds. Reaching unprecedented success throughout the 80’s and 90’s, The Judds sold 20 million records, scored fifteen #1 hits and received over sixty industry awards including six Grammy’s, seven consecutive CMS Vocal Group of the Year awards and ACM’s Top Vocal Duet award.

As the pinnacle of their career, Naomi was stricken with Hepatitis C, a potentially fatal chronic liver disease, incurred from an infected needle when she worked as a registered nurse, cutting short her musical career and forcing her into retirement to battle the disease.

Today, Naomi is a survivor of Hepatitis C and uses her fame, her experience as a former RN and her passion to reach and help people in a variety of mediums including public speaking, film, television and radio shows, including her six-week SiriusXM radio series, “Think Twice” which aired the summer of 2012, and authoring seven books which include two New York Times best-sellers. Meanwhile, Naomi also continues her humanitarian efforts.

On-site conference registration is available for single day passes, the full conference, and preconference seminars (October 25 – 26). Visit the CTC registration desk at the Gaylord Opryland Convention Center. For more information on the CTC and educational offerings, see the Clinical Team Conference information online.

(Online registration  with a reduced registration fee is available through October 2, 2014.)

NHPCO Applauds Passage of the IMPACT Act

Hospice provisions added to the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) will create increased transparency within the hospice community.

This week, the U.S. House of Representatives and Senate passed the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act), legislation which includes hospice integrity provisions that are backed by the hospice community.  The National Hospice and Palliative Care Organization (www.nhpco.org) supports this legislation and the additional oversight it will bring to end-of-life care providers.

The IMPACT Act (H.R. 4994) requires more frequent surveys of hospice providers – a measure the hospice community NHPCO has championed for more than a decade. The bill mandates that all Medicare certified hospices be surveyed every three years for at least the next ten years.

A 2007 HHS Office of the Inspector General report found that current survey measures for Medicare-certified hospices was not providing sufficient oversight.

“Currently, hospices can go eight years or more without ever being surveyed, which is far too long,” said J. Donald Schumacher, NHPCO president and CEO. “More consistent surveys, and the process providers go through to prepare for them, will help hospices and ultimately benefit the patients and families in their care.”

Additionally, the new legislation will facilitate medical reviews for select hospice programs with a soon to be determined percentage/number of patients receiving care for more than 180 days. The specific patient load that would trigger this medical review is yet to be set by CMS.

Such a medical review of what are known as “long stay” patients will help ensure that hospices are appropriately caring for individuals with life-limiting illnesses that are often harder to prognosticate than in the earlier days of hospice provision when most patients had a cancer diagnoses.

NHPCO has supported this provision since it was originally recommended by MedPAC in 2009.

The legislation also includes a provision that would align hospice reimbursement and the hospice aggregate financial cap to a common inflationary index.

“Under NHPCO’s leadership, the hospice community has been on the frontlines of advocating for increased transparency, program integrity, and accountability. We believe that the hospice provisions included in the IMPACT Act are critically important steps in this direction,” stressed Schumacher.

NHPCO reports that more than 1.5 million dying Americans receive care for the nation’s hospice providers every year.

Children with Medical Complexities: Free e-journal

A new edition of the free e-journal published by NHPCO's Children's Project on Palliative/Hospice Services is available online. Children with Medical Complexities, Part One (Issue #36; August 2014) is a free e-journal published by NHPCO’s Children’s Project on Palliative/Hospice Services. This new edition is a collection of articles focused on caring for children with medical complexities. This is the first of two editions looking at this important topic.

As noted in the introduction of one of the articles, “Medically complex and fragile children with progressive diseases present unique and complex challenges for their medical management that require coordination, flexibility, and consistent community…between the family, hospice and medical teams.”

Alison Kirkland, a mother who wrote the article “After the Unexpected Happens,” shares her personal insight: “Despite the heartache and stress, parenting a child with medical complexities can be one of the most joyful and rewarding experiences of your life.”

Additional articles in this issue include:
•    Caring in Uncertainty: Children and Families with Genetic Conditions
•    The Partnership between Palliative Medicine and Children with Medical Complexity
•    Complex Care Coordination
•    Pediatric Palliative Care and Pediatric Surgery: Common Issues
•    Staff Bereavement in Palliative Pediatric Care

Visit the archive page of the ChiPPS e-journal/e-newsletter page on the NHPCO website for access to previous editions of this publication.

New Legislation Introduced to Promote Appropriate Hospice Oversight

Legislation requiring more timely surveys of Medicare-certified hospice care programs was introduced on Friday, August 1, before the House of Representatives adjourned for the August recess.  Led by Congressmen Tom Reed (R-NY) and Mike Thompson (D-CA), the Hospice Opportunities for Supporting Patients with Integrity and Care Evaluations (HOSPICE) Act, HR 5393, is being well-received by the hospice community.

The National Hospice and Palliative Care Organization enthusiastically supports this new legislation and applauds the work of Congressmen Reed and Thompson who are strong champions of hospice care.

The HOSPICE Act would require that hospices be surveyed no less frequently than every three years and authorizes funding for CMS to contract for the additional oversight.

The Office of the Inspector General (OIG) examined hospice survey frequency in 2007 and 2013 and found that the existing intervals and resources were inadequate.  The mandatory survey frequency in HR 5393 is consistent with the OIG recommendations.

Additionally, the new bill will make a technical correction to allow for implementation of existing law requiring CMS to conduct a medical review of hospice programs that reach to be determined threshold of patients under care for more than 180 days.  The threshold would be established by CMS.  NHPCO has supported this provision since it was originally recommended by MedPAC in 2009. 

“These are two important program integrity provision that have long-been supported by NHPCO.  The hospice community is very serious about compliance and protecting the quality of care that is promised by the Medicare Hospice Benefit,” said J. Donald Schumacher, NHPCO president and CEO.

This new bill builds on a provision from the HELP Hospice Act (HR 2302/S 1053) that addresses mandating hospice surveys as a critically important program integrity piece.

2014 Circle of Life Award® Presented

National Hospice and Palliative Care Organization and the National Hospice Foundation honor the recipients of the 2014 Circle of Life Award®.  Presented on July 21 at the American Hospital Association’s annual summit held in San Diego, the award celebrates innovation in end-of-life care and highlights programs that demonstrate superior vision, depth, and scope. 

The 2014 Circle of Life Award honorees are:

• Baylor Health Care System Supportive and Palliative Care Services, Dallas, Texas
• Lehigh Valley Health Network, Allentown, Pennsylvania
• Yakima Valley Memorial Hospital and Foundation, Yakima, Washington

In announcing the honored recipients, AHA emphasized that the programs share overriding themes of creating and championing the role of palliative care through the community.

In addition to the three award winners, AHA presented a Citation of Honor to the Center for Palliative and Supportive Care, Ambulatory Program, University of Alabama at Birmingham.

“These programs serve as models for us all as we move forward in our shared goal of providing the highest quality of care for all those we serve,” said J. Donald Schumacher, NHPCO and NHF president and CEO. “We are proud to celebrate those care providers that are leading the way in innovation and quality care delivery.”

Since 2000, the Circle of Life Award has honored programs that demonstrate excellence and innovation in palliative and end-of-life care. Further information about the honorees and the Circle of Life Award is available at the AHA website.

The National Hospice and Palliative Care Organization and the National Hospice Foundation are major sponsors of the 2014 award, as is the American Hospital Association and the Catholic Health Association of the United States.

Left to right: Dr. Jonathan Perlin, American Hospital Association Board; Dr. Elizabeth Kvale, University of Alabama Birmingham; Diane Patterson, Yakima Valley Memorial Hospital; Donna Stevens, Lehigh Valley Health Network; Dr. Robert L. Fine, Baylor Health Care System; Mary Starmann-Harrison, AHA’s Executive Committee.