CMS Proposes Updates to the Wage Index and Payment Rates for the Medicare Hospice Benefit
On April 21, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule (CMS-1652-P) that would update fiscal year (FY) 2017 Medicare payment rates and the wage index for hospices serving Medicare beneficiaries.
This proposed rule would update the hospice wage index, payment rates, and cap amount for fiscal year (FY) 2017. In addition, this rule would propose changes to the hospice quality reporting program, including proposing new quality measures. The proposed rule also solicits feedback on an enhanced data collection instrument and describes plans to publicly display quality measures and other hospice data beginning in the middle of 2017. Finally, this rule updates hospice monitoring data analysis and provides discussion about ongoing monitoring efforts.
This rule proposes updates to the hospice payment rates for fiscal year (FY) 2017, as required under section 1814(i) of the Social Security Act (the Act). This rule also proposes new quality measures and provides an update on the Hospice Quality Reporting Program (Hospice QRP) consistent with the requirements of section 1814(i)(5) of the Act, as added by section 3004(c) of the Patient Protection and Affordable Care Act (Pub. L. 111-148) as amended by the Health Care and Education Reconciliation Act (Pub. L. 111-152) (collectively, the Affordable Care Act). In accordance with section 1814(i)(5)(A) of the Act, starting in FY 2014, hospices that fail to meet quality reporting requirements receive a 2.0 percentage point reduction to their payments.
Proposed Rule Details
As proposed, hospices would see a 2.0 percent ($330 million) increase in their payments for FY 2017. The proposed 2.0 percent hospice payment update percentage for FY 2017 is based on an estimated 2.8 percent inpatient hospital market basket update, reduced by a 0.5 percentage point productivity adjustment and by a 0.3 percentage point adjustment set by the Affordable Care Act.
As discussed in the FY 2016 Hospice Wage Index and Payment Rate Update final rule (80 FR 47183), CMS implemented changes required by the Improving Medicare Post-Acute Care Transformation Act of 2014 (Pub. L. 113-185) (IMPACT Act). Specifically, for accounting years that end after September 30, 2016 and before October 1, 2025, the hospice cap is updated by the hospice payment update percentage rather than using the consumer price index for urban consumers (CPI–U). As required by section 1814(i)(2)(B)(ii) of the Act, the hospice cap amount for the 2017 cap year will be $28,377.17, which is equal to the 2016 cap amount ($27,820.75) updated by the FY 2017 hospice payment update percentage of 2.0 percent.
As a reminder, in the FY 2016 Hospice Wage Index and Payment Rate Update final rule (80 FR 47142), CMS finalized the alignment of the cap accounting year with the federal fiscal year beginning in 2017. Therefore, the 2017 cap year will start on October 1, 2016 and end on September 30, 2017. Table 26 in the FY 2016 Hospice Wage Index and Payment Rate Update final rule (80 FR 47185) outlines the timeframes for counting beneficiaries and payments during the 2017 transition year.
This rule also updates data analysis regarding hospice trends including diagnosis reporting, pre-hospice spending, non-hospice spending, and live discharges. Ongoing and future monitoring efforts are also discussed and monitoring will occur at the aggregate and provider-levels.
Hospice CAHPS® Experience of Care Survey
The Hospice CAHPS® Survey is a component of the Hospice Quality Reporting Program required under the Affordable Care Act. This proposed rule provides a description of the Hospice CAHPS® Survey, including the model of survey implementation, the survey respondents, eligibility criteria for the sample, and the languages in which the survey is offered, among other details. The proposed rule also outlines participation requirements for the FY 2019 and FY 2020 annual payment updates. For the FY 2019 Annual Payment Update (APU), hospices must collect survey data on an ongoing basis from January through December of calendar year (CY) 2017. For the FY 2020 APU, hospices must collect survey data on an ongoing basis from January through December of CY 2018. The proposed rule also includes survey data submission deadlines for the FY 2018, FY 2019, and FY 2020 APU periods. Public display of the survey results will not occur until CMS has collected at least four quarters of data. CMS anticipates that public display of the data will occur during CY 2017. More information can be obtained at the survey website, www.hospicecahpssurvey.org.
New Hospice Quality Measures
The Hospice QRP is proposing two new quality measures for FY 2017. The first, Hospice Visits When Death is Imminent, is a measure that will assess hospice staff visits to patients and caregivers in the last week of life. The second, Hospice and Palliative Care Composite Process Measure, will assess the percentage of hospice patients who received care processes consistent with guidelines. This measure will be based on select measures from the seven that are currently being submitted under the Hospice QRP (Pain Screening, Pain Assessment, Dyspnea Treatment, Patients Treated with an Opioid who are given a Bowel Regimen, and Treatment Preferences & Beliefs/Values Addressed if desired by patient).
Enhanced Data Collection
CMS is considering enhancing the current Hospice Item Set (HIS) data collection instrument to be more in line with other Post-Acute Care settings. This revised data collection instrument would be a comprehensive patient assessment instrument, rather than the current chart abstraction tool. By integrating a core standard data set into a comprehensive assessment system, hospices can use such a data set as the foundation for valid and reliable information for patient assessment, care planning, and service delivery. This will enable greater accuracy in quality reporting; decrease provider burden; help surveyors ensure hospices are meeting Conditions of Participation (CoP) and providing high quality patient care; and, in the future, enable payment determinations.
CMS expects to begin public reporting via a Compare Site in CY 2017. In addition, CMS expects to post hospice demographic data on a public use file at https://data.medicare.gov in late spring/early summer 2016.
The proposed rule went on display on April 21 at the Federal Register’s Public Inspection Desk and will be available under “Special Filings,” at http://www.federalregister.gov/inspection.aspx.
For further information, see http://www.cms.gov/Center/Provider-Type/Hospice-Center.html. Public comments on the proposal will be accepted until June, 2016.