CMS, NAHC Seek Input on Hospice Proposed Rule
Recording of NAHC Web Event Providing Analysis of Proposed Rule Remains Available
May 12, 2016 09:09 AM
As reported in the April 22, 2016 NAHC Report, CMS released the Medicare Program; FY2017 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements (CMS-1652-P), the proposed payment and policy rule for the Medicare hospice benefit for fiscal year (FY) 2017. Since the FY2016 rule contained significant payment refinements and other payment-related policy changes, the rule (as anticipated) focuses more heavily on hospice quality issues. CMS is seeking input on all components of the proposed rule, but we would like to draw your attention to the following areas:
1. CMS proposes use of two new hospice quality reporting program (HQRP) measures (beginning April 1, 2017):
a. Hospice Visits When Death is Imminent- assessing hospice staff visits to patients and caregivers in the last week of life; and
b. Hospice and Palliative Care Composite Process Measure- assessing the percentage of hospice patients who received care processes consistent with existing guidelines
2. Comprehensive Patient Assessment Instrument
CMS is considering developing a new data collection mechanism for use by hospices -- a hospice patient assessment instrument -- which would serve two primary objectives concordant with the Affordable Care Act legislation: (1) to provide the quality data necessary for HQRP requirements and the current function of the HIS; and (2) to provide additional clinical data that could inform future payment refinements. This assessment would take the place of the existing HIS admission and discharge instruments.
3. Public Reporting, Hospice Compare Site, and Star Rating
CMS anticipates that public reporting of the eligible HIS quality measures on the CMS Compare Web site for hospice agencies will begin sometime in the spring/summer of CY 2017. CMS is prepared to share HQRP information such as hospice demographic data and general information about hospice data publicly on the Data.Medicare.gov website in CY2016.
CMS has determined that all seven HIS measures are eligible for public reporting. Therefore, CMS plans to publicly report all seven HIS measures on a CMS Compare Web site for hospice agencies. Individual scores for each of the seven HIS measure scores would be reported.
Consistent with many other CMS CAHPS® surveys that are publicly reported on CMS Web sites, CMS will publicly report hospice data when at least 12 months of data are available, so that valid comparisons can be made across hospice providers in the United States, in order to help patients, family, friends, and caregivers choose the right hospice program.
A Hospice Compare site is currently under development. Like other CMS Compare Web sites, the Hospice Compare Web site will, in time, feature a star rating system of 1 to 5 stars for each hospice. Hospices will have prepublication access to their own agency’s quality data, which enables each agency to know how it is performing before public posting of data on the Hospice Compare Web site. CMS will announce the timeline for development and implementation of the star rating system in future rulemaking.
4. NQF-endorsed Hospice Quality Reporting Measures
Quality measures selected for the HQRP must be endorsed by the NQF unless they meet the statutory criteria for exception under section 1814(i)(5)(D)(ii) of the Act. CMS proposes to codify that if measures currently used in the HQRP undergo non-substantive changes in the specifications as part of their NQF re-endorsement process, CMS would subsequently utilize the measure with the new endorsed status in the HQRP without going through new notice-and-comment rulemaking.
5. CAHPS Hospice Survey Participation and Exemption
CMS proposes that hospices that received their CCN after January 1, 2017, are exempted from the FY 2019 APU Hospice CAHPS® requirements due to newness. This exemption will be determined by CMS. The exemption is for 1 year only. Likewise, CMS proposes the same for hospices that receive their CCN after January 1, 2018 (exempted from the FY 2020 Hospice CAHPS® requirements due to newness.)
6. Estimate of the Information Collection Burden
CMS is seeking information on the accuracy of the estimate of the information collection burden and the quality, utility, and clarify of the information to be collected as well as recommendations to minimize the information collection burden. More information on this can be found in Section IV of the proposed rule.
NAHC and its affiliate, the Hospice Association of America (HAA), sponsored a web event in which a few hundred stakeholders participated on April 27, 2016. NAHC President Val J. Halamandaris, Theresa Forster, and Katie Wehri provided detail and analysis of the proposed rule during the one-hour session. Click here to order or access a recording/materials related to the web event.
NAHC and HAA are crafting comments to CMS and request your feedback on any of the issues outlined above. In order for your views to be considered for inclusion in NAHC’s comments, please submit your feedback to email@example.com or Katie@nahc.org by June 10, 2016. We also encourage you to submit comments directly to CMS (instructions can be found in the proposed rule).