More Change on the Horizon for Hospices: The CMS FY 2016 Proposed Rule

06/08/15 Written by 

Hospices are facing even more change with the CMS FY 2016 proposed rule that was released on April 30, and will affect the wage index and payment rates for the Medicare Hospice Benefit. It is important to review these changes closely in order to understand how your reimbursement will be affected. It’s estimated that the overall impact of this proposed rule is close to $200 million in increased payments to hospices.

Here is a high-level overview of what will affect your reimbursement:

  1. CBSA Census Designations: Take notice as to whether your county is designated as rural or urban. This can have an impact on your reimbursement based on which designation is given according to the 2010 census.
  2. Claim Form Diagnoses: ALL diagnoses must be reported in the initial and comprehensive assessments on hospice claims, even if they are not related to the terminal prognosis.
  3. Two-tiered Reimbursement for Routine Home Care (RHC): According to an analysis of 2013 cost report data, a high percentage of patients were not receiving skilled visits during their last days of life. Because of this, a dual-level reimbursement has been proposed by CMS: (1) Higher base payment for the first 60 days and (2) reduced base payment for over 61 days of hospice care.
  4. Service Intensity Add-on (SIA Payment): This would result in an add-on payment, equal to the Continuous Hospice Care hourly payment rate, if certain criteria are met: (1) RHC level of care day, (2) occurs during the last 7 days of life, (3) direct patient care is provided by an RN or SW, and (4) service is not provided in a skilled nursing facility/nursing facility.

Concerning changes with the Hospice Quality Reporting Program (HQRP), there were several other topics related to hospice care that were discussed and outlined in this rule that will affect hospices moving forward. To start, CMS will continue with the 7 NQF-endorsed quality measures from HIS, with no new measures proposed for FY 2017. They also clarified that they will focus on several areas to be used for future measure development. The first of which is a pain outcome measure that allows for someone other than the patient to report on pain. They are also looking at claims-based measures focused on care practice patterns to include: skilled visits in last days of life, burdensome transitions in and out of hospice, and live discharge rates. Responsiveness of the hospice to patient and family care needs is also a hot topic that may see future measure development, along with hospice team communication and care coordination.

If you are a new facility, data submission will be required based on the date that your CCN notification letter is received. If it is before November 1, 2015, you must submit data for 2015, otherwise you are exempt for this year. Starting in 2016, hospices must begin submitting quality data on patient admission starting on the date that they receive their CCN notification.

One big update for Hospice CAHPS in the discussion is that there are now 11 proposed quality measures that are being submitted to NQF. This is good news if you are using Deyta as your Hospice CAHPS survey vendor as all 11 quality measures are already included in Deyta’s Dashboard Report. Another benefit is Deyta’s large database that provides meaningful benchmarking and analysis with a comprehensive suite of reports, since public reporting on this data will not happen until at least 12 months of data are collected. The submission deadline has been updated to be the second Wednesday of the month, and Q2 2015 data submission has been updated with a due date of November 11, 2015.

In regards to HIS data submission, all records must be submitted within the 30-day time frame. To be compliant with HIS submission, the thresholds required for record submission rise by 10% each year, starting at 70% for 2016. The public reporting aspect of HIS data will be determined once CMS can fully review the data. Validity and reliability of the quality measures are being analyzed using data from Q4 of 2014 through Q3 of 2015, while data from Q1 2015 through Q4 2015 will be used to determine which measures will be publicly reported. Provider-level feedback reports will be available on CASPER with facility-level scores, benchmarks, and thresholds. This should be available during 2015 for hospices to use as part of their QAPI program.

CMS will be accepting public comments on the proposed rule until June 29, 2015 and anticipates the final rule to be published in August 2015.

Position your hospice for success with Deyta and HEALTHCAREfirst!

Deyta is now a division of HEALTHCAREfirst; offering hospices access to even more industry-leading solutions and services. With Deyta and HEALTHCAREfirst, hospices will stay ahead of these proposed changes by ensuring accurate billing and coding, simplifying HQRP compliance, and gaining valuable insights needed to drive performance improvement ahead of public reporting. Contact us to learn more at 888.893.1937 x151 or [email protected]

Kristen Bright

Kristen Bright is a dedicated professional with a diverse background in healthcare marketing, communications, and human resources. Prior to joining Deyta in March of 2015, she earned her BA in Integrated Strategic Communication from the University of Kentucky and spent five years working within the assisted living industry. As the Marketing Manager, Kristen works to develop valuable resources to establish Deyta as the leader in advanced analytics and data-driven management solutions for home health and hospice organizations.
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