On April 27, 2017, the Federal Register posted the FY2018 Hospice Wage Index proposed rule for public inspection. Download the proposed rule, public inspection version (PDF).
Overall,
the Notice of Proposed Rule Making is both encouraging and discouraging for
providers in the U.S. hospice community. NHPCO is pleased that CMS is recognizing the regulatory and administrative burdens
facing the hospice community, and that CMS is trying to find ways to not add to
that burden. We applaud the effort and recognition of the challenges of serving
our nation’s patients and families.
Market Basket
Increase
Unfortunately, the statutory limitation of the FY 2018 market basket to no more
than a one percent increase, when the NPRM notes that it should be at least
twice as much (2.2 percent) further burdens the community facing
ever-increasing costs, and forces hospice providers to do more with less.
Quality Measures
and Public Reporting
The hospice community is encouraged that CMS continues its efforts toward
developing and implementing quality measures and public reporting, including a
Star rating system. At the same time,
the hospice community is concerned about the use of claims data as the basis of
new measures. Also, it appears that CMS
is intent on merely documenting the amount of continuous care and general
inpatient care that is delivered, rather than assessing the actual needs of
patients and how the hospice community is meeting those more intense clinical
needs.
Patient Eligibility
and the Physician’s Role
While CMS notes it is soliciting comments about the underlying documentation
that is used, or should be used to determine patient eligibility, they seem to
be ignoring the persistent problem of short hospice stays.
The
thrust of their inquiry seems to be directed toward hospice physicians being
required to review and reference the attending physician’s medical notes prior
to the initial certification of a patient as eligible for hospice, or even
requiring a face-to-face encounter with the hospice physician, prior to
certification. The hospice community
already deals with patients dying during the admissions process, and with
approximately 25 percent of hospice patients dying within seven days, and more
than half within two weeks, waiting for patient records, or an appointment with
the hospice physician, would be a cruel and inhumane process that would deny
patients the very care they need.
Unless
and until there is universal electronic medical records and the medical records
are accessible across all care settings, this approach is very troubling
indicator of a lack of understanding of what patients and families are going
through and the devastating impact that it could have on hospice admissions.
CMS
did note that the level of live discharges, from all causes, had remained
relatively constant at 17 percent and as such, didn’t reveal any anomalies.
SIA Impact
CMS also noted that the Service Intensity Add-on didn’t seem to have influenced
the number or duration of visits by clinical specialists in the last seven days
of life. As the hospice community
continues to make adjustments under the new payment system, this bears
additional review.
We
look forward to a very engaged and collaborative working relationship with CMS
to provide insights and actual operational impact examples of their proposals.
NHPCO members will find a regulatory alert offering more detailed analysis available on the NHPCO website.
