MedPAC Submits Comments on FY2017 Proposed Rule on Hospice Payment, Quality
June 13, 2016 09:09 AM
In late May, the Medicare Payment Advisory Commission (MedPAC) submitted comments to Andrew Slavitt, Acting Administrator of the Centers for Medicare & Medicaid Services (CMS) on CMS-1652-P: Medicare Program; FY 2016 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements. The comment letter is available online here. MedPAC focuses the bulk of its comments on proposed hospice quality measures and related initiatives, on CMS’ plans to monitor the impact of payment reform, and on urging that CMS aim program integrity efforts at aberrant patterns of care by some hospice providers.
MedPAC’s letter references the two new quality measures -- the two-part (paired) measures related to visits in the final days of life and the composite measure aggregating performance across the seven existing Hospice Item Set (HIS) measures -- as well as CMS’ plans to create a hospice assessment instrument that would include the current HIS measures. MedPAC expresses support for the proposed new measures, and is particularly supportive of the “paired” measures related to visits at the end of life. Despite MedPAC’s expressed support, its letter cautions that it is better to have a smaller number of “meaningful quality measures,” and advises that CMS continue to assess existing measures, eliminate those that no longer provide value, and consolidate measures where possible as the hospice quality program evolves. MedPAC also articulates strong support for the development of outcomes measures for hospice, as well as measures indicating live discharge rates.
MedPAC’s comment letter also expresses support for “real-time monitoring of hospice utilization, service delivery, and payments,” and recommends that CMS focus program integrity efforts on “those providers where the data suggest scrutiny is most warranted.”
The National Association for Home Care & Hospice (NAHC) is developing comments on the proposed FY2017 hospice rule that will echo some of MedPAC’s comments, including those which express support for development of meaningful outcomes measures, elimination of unnecessary measures as the quality program develops, and which recommend focusing program integrity efforts on aberrant providers. Talking points related to NAHC’s planned comments will be published in a forthcoming issue of NAHC Report.