MedPAC Comments on Proposed Hospice Payment Changes
Opposes CMS’ Plans to Deny SIA for NF/SNF Patients
June 5, 2015 10:15 AM
The Medicare Payment Advisory Commission (MedPAC) has submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed payment reform rule that was issued April 30. As part of the letter, MedPAC supports CMS’ proposed modifications to the structure of the payment rates for routine home care (RHC) as a “positive step toward better aligning hospice payments with the…pattern of hospice visits throughout an episode.” Relative to the Service Intensity Add-on (SIA) permitted for RN and Social Worker visits within the last seven days of life, MedPAC “urges CMS to permit these payments for hospice patients in nursing facilities because regardless of setting we would expect hospice patients to have increased needs for nursing support and symptom management in the last days of life.” The National Association for Home Care & Hospice (NAHC) is in the process of developing comments on the proposed regulation, which are due by 5 p.m. on June 29, but shares MedPAC’s concern about the disallowance of the SIA for patients in nursing facilities or skilled nursing facilities. The overriding goal of hospice payment reform should be to more appropriately reimburse hospice providers for the cost of delivering needed services rather than to pay them differentially based on the location of the patient’s residence or to discourage the provision of needed services.
MedPAC views CMS’ planned implementation of a higher RHC rate for days 1-60 of care, and a lower rate for day 61 and subsequent days, as a “conservative” but “reasonable initial approach” that is “straightforward to implement and has the effect of increasing payments in the beginning portion of the episode and reducing payments later in the episode.” MedPAC does raise issues as to whether the changes are sufficient to address higher costs related to short-stay patients, but sees the changes as leaving room for finer base rate categories in future years if data indicate they are warranted. MedPAC does not support lengthening the period of time for which the higher initial RHC rate would be applicable.
MedPAC also expresses support of CMS’ proposed policy that days of care “follow the patient” such that if a patient is discharged alive from hospice care the episode day count continues until after 60 consecutive days of non-hospice care have passed. MedPAC sees this as necessary to minimize financial incentives for hospice patients to be enrolled and disenrolled, or transferred between hospices. MedPAC does not support shortening of the time frame (60 days between hospice discharge and the readmission to hospice care) that would trigger a new episode of care and the higher rate for RHC. MedPAC also comments on the lack of clarity as to how the new payment system will be implemented relative to patients on care at the beginning of the 2016 fiscal year, and suggests that CMS apply the new payment rates for RHC based on the day within the episode of care that the patient is in at the time the new payment rates become effective.
As mentioned previously in this article, MedPAC expresses concerns about CMS’ plans to exclude patients in the nursing facility setting from eligibility for the SIA payment as -- regardless of setting -- patients will likely have an “increased need for nursing support to manage their symptoms in the last days of life.” MedPAC suggests that a more appropriate approach to addressing perceived lower costs of providing care in a nursing home would be to adjust the RHC rate for patients in nursing facilities.
MedPAC also comments on CMS’ plan to annually recalibrate budget neutrality between expenditures for RHC and the SIA and supports that action.
In brief comments on CMS’ plans for continuing development of hospice quality measures and in keeping with perspectives presented as part of its March 2015 Report to Congress, MedPAC supports CMS’ expressed intent to develop claims-based quality measures (such as measures based on live discharge rates, skilled visits in the last days of life, and burdensome transitions in and out of hospice), as well support for development of measures that focus on outcomes, including pain.
NAHC will be developing comments on the FY2016 proposed hospice payment rule. NAHC member agencies, vendors and consultants that have questions or comments they would like to have considered for inclusion in NAHC’s comments on the rule should send them to Theresa Forster at firstname.lastname@example.org.