MedPAC Delays Consideration of Including Hospice in Post-Acute Transfer Policy
NAHC Cautions Policy is “Inadvisable”
March 17, 2015 04:33 PM
As previously reported, the Medicare Payment Advisory Commission (MedPAC) has been examining hospitals’ increased use of “observation status” and its impact on beneficiaries and other stakeholders with an eye toward development of recommendations to clarify policies governing use of short-term inpatient stays. As part of these discussions, MedPAC has referenced policy changes that could help offset increased costs that would result from hospital short-stay policy recommendations. Among the options under consideration is expansion of the post-acute hospital transfer policy to include “early” discharges to hospice care. Extension of the post-acute transfer policy to include hospice was examined by the Department of Health and Human Services’ Office of the Inspector General (OIG) in a May 2013 report, “Medicare Could Save Millions by Implementing a Hospital Transfer Payment Policy for Early Discharge to Hospice.”
At its March meeting, MedPAC indicated that, rather than considering a recommendation on including hospice in the post-acute transfer policy at this time it intends to explore the issue in greater depth as part of future meetings before issuing a recommendation.
In discussions with MedPAC staff, the National Association for Home Care & Hospice (NAHC) has expressed concern about extension of the post-acute transfer policy to hospice. Most recently, NAHC sent a letter to MedPAC Chairman Glenn Hackbarth and members of the Commission, expressing the belief that, “…after careful consideration…of extending the transfer policy to hospice, MedPAC will determine that making such a recommendation is inadvisable at this time.” NAHC’s letter notes that election of hospice care represents a decision to forego curative care, and that post-acute care discharge to hospice represents a “shift in focus of treatment….The circumstances are substantially different from those in play with existing post-acute transfer policies, under which services might be considered to be a continuation of treatment that was started as part of a patient’s hospitalization.”
NAHC’s letter suggests that imposition of a post-acute transfer policy on discharges to hospice will “create a strong financial incentive for hospitals to retain patients on care, thereby delaying the start of hospice services and increasing the incidence of very short hospice stays.” The letter also notes that “early” discharges from hospital to hospice care in many cases are patients that would have benefitted from referral to hospice weeks or months previously, and encourages MedPAC to look more broadly at issues related to discharge planning and referral for care as patients approach the end of life. Improvements in care planning for the terminally ill could ensure patients receive more appropriate care and yield Medicare savings.
Here is a link to NAHC’s full letter to MedPAC.