FY2024 Hospice Medicare and Medicaid Base Rates – At a Glance

NAHC

Beginning October 1, 2023, hospice base payment rates will increase by 3.1 percent, as published in the final FY 2024 Hospice Payment Rule.  As is customary, the Medicaid program waits until Medicare rates are finalized to issue guidance on the applicable corresponding hospice payment rates. The Centers for Medicare & Medicaid Services (CMS) Medicaid Financial Management Group recently issued a memorandum  containing the minimum Medicaid hospice rates that will be applicable for FY2024.

Hospices should note that the hourly rate for Continuous Home Care ($65.23 under Medicare and $65.25 for Medicaid) will be the rate applicable to the Service-Intensity Add-on (SIA) applied to certain in-person visit hours delivered by RNs and Social Workers in the last week of life while a patient is on Routine Home Care (RHC). 

Medicare and Medicaid rates vary slightly due to consideration of potential copayments that are included when calculating the Medicare rates but not those for Medicaid.

Recently CMS also issued Transmittal 12193/Change Request 13289, which communicates the Update to Payment Rates, Hospice Cap, Hospice Wage Index and Hospice Pricer for FY2024 to the Medicare Administrative Contractors (MACs).

Both of these communications – the Medicaid Financial Management Group Memorandum and Transmittal 12193 – provide a breakdown of the labor and non-labor portion of the rates for use when applying the wage index  and include information on rates that will be applicable for those hospices that failed to meet the quality reporting requirements applicable to FY2024.  

Effective beginning with FY2024, section 1814(i)(5)(A)(i) of the Social Security Act was amended by the Consolidated Appropriations Act of 2021 (CAA) to increase the payment reduction for Medicare hospices who fail to meet hospice quality measure reporting requirements from 2 percentage points to 4 percentage points. Medicaid minimum rates would be reduced by the amount of any penalty due to non-reporting provided a state has chosen to implement this optional Medicaid hospice rate reduction for lack of quality reporting and imposition of the penalty as well as the penalty percentage has been specified in the Medicaid state plan.

The TABLE below contains a comparison drawn from these two documents of the FY2023 Medicare and Medicaid rates. The labor portion of these rates must be further adjusted by the wage index. It should be noted that CMS will continue to follow a policy put into effect beginning with FY2023 under which reductions in wage index values from one year to the next will be limited to a drop of 5 percent. The table below contains the new labor shares for the daily payment rates.

The hospice Aggregate Cap for the year ending September 30, 2024, is $34,494.01.

FY 2024 Medicare Hospice Payment Rates under MEDICARE and MEDICAID*

Invitation to Participate in ‘Patients’ Right to Know” Act Stakeholder Process (re: HB23-1218)

Colorado Department of Public Health and Environment (CDPHE)

You are invited to participate in the stakeholder process regarding the “Patients’ Right to Know” Act, or HB23-1218, a law passed by the Colorado Legislature in the 2023 session. This new law requires hospitals, rehabilitation hospitals, freestanding emergency departments, and licensed community clinics to make publicly available a list of the health care services which are generally available or subject to significant restriction specifically relating to health care in three areas:

• Reproductive health-care services;
• LGBTQ health-care services; and
• End-of-life health-care services.

In response to the new law the Division will develop, in collaboration with stakeholders, a “Service Availability Form.” Once the form itself is developed, the Division will work to establish rules which bring the law into the pertinent health facility licensing chapters. Once the form is finalized and published, the affected health facilities will be required to provide this form to patients, members of the public, and the Department for public display. For more information, please see the whitepaper here. 

Our first monthly meeting will be Tuesday, September 26th, 2023, from 12:30 pm to 3:30 pm, and on the fourth Tuesday of the month thereafter until the process concludes in spring 2024.

Notice will be emailed directly to all individuals who sign up to receive such messages. Please sign up here. Please feel free to share this link with other interested parties.

All who are interested are welcome to attend and participate. Meeting documents, including agendas, proposed rule language, presentations, etc., will be posted to the public meeting drive no later than a week before each meeting. 

You are receiving this email because you signed up to the interested parties list for this project. If you wish to no longer receive these emails, please reply to this email with that request.

If you have any questions or comments prior to the meeting, feel free to contact myself, Ash Jackson at [email protected], or Alexandra Haas, at [email protected].

Best Regards,

Ash Jackson, Policy Advisor
Policy & Regulation Services
CDPHE

Who Should Get a COVID Vaccine This Year?

Reuters | By Michael Erman

(Reuters) - The U.S. drug regulator authorized updated COVID-19 vaccines from Pfizer and its partner BioNTech as well as from Moderna on Monday as the country prepares to start an autumn vaccination campaign as soon as this week. A third vaccine from Novavax remains under review.

The U.S. Food and Drug Administration approved the shots for those aged 12 and above, and authorized them for emergency use in children aged 6 months through 11 years. Advisers to the U.S. Centers for Disease Control and Prevention are set to meet on Tuesday to discuss recommendations on who should get the vaccines this year. CDC Director Mandy Cohen said last month she expects the shots to be given annually, but not all doctors agree everyone needs them each year.

How is this year's vaccine different from last year?

Pfizer with BioNTech, Moderna and Novavax all have created new versions of their COVID-19 vaccines. Unlike last year's booster shot that included the original strain of the virus and the then-dominant Omicron variant, this year's shot targets only XBB.1.5, the predominant variant through most of 2023.

The companies have said their retooled vaccines have been shown in early testing to work against newer Omicron subvariants now circulating, including the highly mutated BA.2.86.

Should seniors, the immunocompromised and pregnant people get the shot this year?

There is broad consensus among doctors that these groups should receive at least an annual COVID-19 vaccine to protect against the virus because of their elevated risk of severe disease, hospitalization and death. For instance, the British government's vaccine committee said only adults 65 and older and some of these other categories will be offered the shot as they are the most likely to benefit…

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For Home Health Providers, Finding The Right Revenue Mix Is Increasingly A ‘Balancing Act’

Home Health Care News | By Andrew Donlan
 
Consolidation in the home health market has been forecasted for years.
 
While the amount of home health agencies has declined over the last couple of years, larger consolidation has yet to hit the industry.
 
But the fragmented and growing home health space could finally begin to experience it in the near-term future, likely due to declining traditional Medicare payment rates and a growing Medicare Advantage (MA) population.
 
Those factors are troublesome for almost all home health providers, but they also offer M&A opportunity.
 
“I think the the rate environment that we’re experiencing, whether it’s through Medicare or Medicare Advantage, is going to put some pressure on small players,” VitalCaring CEO April Anthony said on a panel at Home Health Care News’ FUTURE conference. “I think if you don’t have some of those Medicare Advantage relationships, at a point, that becomes a limiting factor to your ability to grow. I anticipate a fair amount of consolidation, in spite of the fact that this might not be the highest multiple era that we’ve experienced in our last few years.” …
 
The Balancing Act
 
When it comes to poor payment rates, Anthony chose to focus on MA plans’ rates for home health services, as opposed to the Centers for Medicare & Medicaid Services’ (CMS) fee-for-service payments.
 
“It’s frustrating to see where Medicare is going with their rates, and what they’re trying to do with clawbacks,” Anthony said. “But, if one of our managed care partners came to us with those [traditional Medicare] rates, we would be jumping for joy. We’d be saying, ‘This is the greatest contract we could possibly hope for.’”
 
Healing Hands Healthcare CEO Summer Napier – while recognizing that MA’s presence is growing quickly – warned other home health providers in the room about getting “into network” with an MA plan.

Being within a network can be beneficial for some providers from a referral perspective, but the risk-reward needs to be calculated on an individual basis.
 
“You can be so eager to get into network or go after a contract that it ends up worse for you than you were without it,” Napier said on the panel. “I think some of the smaller organizations here want to be like the bigger organizations. And so you go after a contract, and then you get into the network. And then, you’re making a third of what you were making being out of network.”…

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