NHPCO Regulatory Alert: FY 2024 Hospice Wage Index and Quality Reporting Final Rule has Been Posted
Summary at a Glance
In the 4:15 posting of the Federal Register for July 28, 2023 the FY 2024 Hospice Wage Index and Quality Reporting final rule was posted to the public inspection part of the Federal Register. The rule for fiscal year 2024 includes the following:
Final FY 2024 rate increase: 3.1% which is a 0.3 percentage point increase from the FY 2024 proposed rule. Rates for each level of care are available in the full analysis of the final rule.
- Cap amount: The hospice cap amount for the FY 2024 cap year is $33,494.01, which is equal to the FY 2023 cap amount ($32,486.92) updated by the FY 2024 hospice payment update percentage of 3.1 percent.
- HOPE Tool: CMS states it will provide additional information on the HOPE Tool test results on the HQRP website in fall 2023.
- Update on Future Quality Measure (QM) Development: CMS appreciated the comments on future QM development and will continue to engage stakeholders in the development of measures.
- CAHPS Hospice Survey Experiment: CMS provided an update on a survey-mode experiment and stated any new modes for completion of the survey would be released with detailed information.
- Hospice Certifying Physician Medicare Enrollment or Valid Opt-Out: On May 1, 2024, hospice certifying physicians, including hospice physicians and hospice attending physicians, will be required to be enrolled in Medicare or validly opted-out.
The CMS Fact Sheet on the final rule describes additional details of the rule. Final FY 2024 Hospice Wage Index values were also posted. The FY 2024 Final State/County Rate Charts are available and can now be used for FY 2024 budget purposes. CMS accepted and responded to many of the recommendations NHPCO advocated for in our comment letter.
A full analysis of the Final Rule is available for NHPCO members.
- Any questions can be directed to [email protected] with “FY 2024 Hospice Final Rule” in the subject line.
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Bipartisan House Lawmakers Introduce Preserving Access to Home Health Act to Protect Patients from Harmful Home Health Program Cuts
PQHH-NAHC Press Statement
New report underscores need for policies to ensure timely patient transition to home health following hospitalization
Washington, D.C. – The Partnership for Quality Home Healthcare (PQHH) and the National Association for Home Care & Hospice (NAHC) today commended Representatives Terri Sewell (AL-7) and Adrian Smith (NE-3) for introducing the Preserving Access to Home Health Act of 2023 in the U.S. House of Representatives. If enacted, the bill would safeguard access to essential, home-based, clinically advanced healthcare services by preventing the Centers for Medicare & Medicaid Services (CMS) from implementing cuts as high as $20 billion over the next decade.
“The Medicare home health community strongly supports this legislation and thanks Representatives Sewell and Smith for their leadership on a Medicare issue that truly threatens access to care for the more than 3 million beneficiaries who rely on this care,” said William A. Dombi, President of the National Association for Home Care & Hospice. “The home health community calls on Congress to ensure the stability that patients and providers urgently need. Since Medicare has again proposed deep cuts to home health in 2024, Congress must act to protect the care their constituents prefer and want.”
Specifically, the bill is designed to address cuts made to home health by CMS during the implementation of Medicare’s Patient Driven Groupings Model (PDGM) by making the following policy changes:
- Repealing permanent and temporary Medicare payment adjustments. The bill would repeal the requirement that CMS make determinations related to the impact of behavior changes on estimated aggregate expenditures. The legislation would eliminate CMS’s authority to adjust home health payments based on such determinations under PDGM. This change would take effect, and be implemented, as if it were included in the Bipartisan Budget Act of 2018, which included home health provisions that led to PDGM implementation.
- Instructing MedPAC to analyze the Medicare Home Health Program. The bill instructs MedPAC to review and report on aggregate trends under Medicare Advantage, Medicaid, and other payers and consider the impact of all payers on access to care for Medicare home health beneficiaries. To verify MedPAC’s calculations, the Commission would be required to make its calculations public. This provision would also add requirements for Medicare home health cost reports to include data on visit utilization and total payments by program.
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CMS Unveils Dementia-Focused Payment Model with Interdisciplinary Care Approach
Hospice News | By Jim Parker
The U.S. Centers for Medicare & Medicaid Services (CMS) has unveiled a new payment model demonstration geared toward dementia-related illnesses, which are becoming more prevalent among hospice patients.
The Guiding an Improved Dementia Experience (GUIDE) Model is designed to improve the quality of life for dementia patients and their caregivers by addressing behavioral health and functional needs, as well as better coordinating care and improving care transitions between community, hospital and post-acute settings.
“While we have made tremendous progress in improving care for people with dementia through the National Plan to Address Alzheimer’s Disease, people living with dementia and their caregivers too often struggle to manage their health care and connect with key supports that can allow them to remain in their homes and communities,” CMS Administrator Chiquita Brooks-LaSure said in a statement. “Fragmented care contributes to the mental and physical health strain of caring for someone with dementia, as well as the substantial financial burden.”
Participating patients and families will also have access to a care navigator to help them access clinical and non-medical services.
Patients will be stratified into one of five tiers, based on a combination of their disease stage and caregiver status. Care intensity and payment increase by tier, according to CMS.
Reimbursement through the model includes a per-member, per-month payment, as well as an infrastructure payment for some safety net providers. Participating operators may also receive payment for respite care.
Patients who have elected the Medicare Hospice Benefit are not eligible for the program. However, hospice and palliative care providers that offer upstream services may be uniquely suited to implement such a model, either directly or through a partnership.
GUIDE involves a trained interdisciplinary care team that delivers a standardized set of services based on a person-centered care plan, according to CMS.
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GUIDE Webinar
CMS will host a webinar to provide more information on the GUIDE Model. During the session, the GUIDE team will discuss the goals of the model, participant and beneficiary eligibility criteria, care delivery requirements, and model payment.
- Date: Thursday, August 10 at 2 p.m. – 3 p.m. ET
- Registration: To register, click here
Interested in GUIDE?
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NAHC Meets with CMS Administration on Medicaid Access Proposed Rule
On Friday, July 21, 2023, the National Association for Home Care & Hospice (NAHC) and our partner organizations, including PMHC, HCAOA, and ANCOR, met with key members of the CMS Administration, including Administrator Chiquita Brooks-LaSure, Senior Advisor Hannah Katch, and Director of the Center for Medicaid and CHIP Services Daniel Tsai. During the conversation, the group discussed the Medicaid Access Proposed Rule, including provisions the associations support, challenges with implementation timelines, and the proposed 80% requirement for direct care worker compensation.
Notably, during the discussion of the 80% rule, CMS raised concerns about using state rate-setting data as a basis for analysis, citing their belief that the state reimbursement methodology may be incorporating inappropriate margins into the calculations.
NAHC and our partners will continue to collect information and data to analyze and understand the impact of the rule as well as to identify information that will help refute the misunderstanding regarding the methods used for state rate setting.
For more information about this meeting or the Access Rule, contact Damon Terzaghi, Director of Medicaid Advocacy, at [email protected] |
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