IMPACT Act’s “Spending per Beneficiary” Measure to include Hospice Payments
July 8, 2016 11:38 AM
Since passage of the Improving Post-Acute Care Transformation Act of 2014 (IMPACT Act), the Centers for Medicare & Medicaid Services (CMS) has been working to develop cross-cutting measures that will be applicable to post-acute care providers (home health agencies, skilled nursing facilities, inpatient rehabilitation facilities, and long term care hospitals). One set of measures with potential implications for hospice that will be applicable to most PAC providers beginning October 1, 2016, are the Medicare Spending Per Beneficiary -- Post Acute Care (MSPB-PAC) measures. Home health providers will be subject to the MSPBPAC measure beginning in January 2017.
The MSPB-PAC measures were developed by Acumen LLC with the goal of “support[ing] public reporting of resource use in all four PAC provider settings as well as to provide actionable, transparent information to support PAC providers’ efforts to promote care coordination and improve the efficiency of care provided to their patients.” When the draft specifications for the MSPB-PACmeasures were published in early 2016, CMS requested comment on a number of issues related to the measures, including the planned inclusion of hospice occurring during a defined post-acute “episode” time frame as “associated services”. This means that hospice spending would be included as part of the total resources used during the post-acute care episode because it is believed that these services may be “reflective of and influenced by the serviced rendered by the PAC facility.”
The National Association for Home Care & Hospice (NAHC) and other hospice stakeholders expressed concern about the inclusion of hospice as an “associated service” because hospice is not a post-acute care service, and NAHC believes that hospice care does not serve as an alternative site of care or as the “next stage” in the continuum of care for achieving the goals of acute hospitalization or post-acute care. Rather, it represents a change in the focus of care and an acknowledgement of the presence of a life-limiting illness. Under most circumstances hospice would not be part of the planned progression of care following acute hospitalization unless a terminal illness was discovered during the course of inpatient or post-acute care treatment. NAHC expressed concern that, among other potential negative consequences, inclusion of all hospice spending in the MSPB-PAC could deter or delay appropriate referrals to hospice care.
In response to these expressions of concern, CMS and Acumen have determined that, while they still plan to include hospice as an “associated service” under the MSPB-PAC measure, they now propose to risk adjust so that episodes including hospice care will only be compared against a benchmark reflecting other MSPB-PAC episodes containing hospice services. Following is the explanation provided by CMS as part of the Medicare and Medicaid Programs; CY 2017 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements; Proposed Ruleon this topic:
”During the public comment period that ran from January 13 to February 5, 2016…we sought and considered public comment regarding the treatment of hospice services occurring within the MSPB–PAC HH QRP episode window. Given the comments received, we propose to include the Medicare spending for hospice services but risk adjust for them, such that MSPB–PAC HH QRP episodes with hospice are compared to a benchmark reflecting other MSPB–PAC HH QRP episodes with hospice. We believe that this provides a balance between the measure’s intent of evaluating Medicare spending and ensuring that providers do not have incentives against the appropriate use of hospice services in a patient-centered continuum of care.”