CMS Open Door Forum Summary: Hospice

The Centers for Medicare and Medicaid Services (CMS) held a Home Health, Hospice, and DME Open Door Forum on September 21, 2022. The summary of the Forum applicable to hospice providers is below. Care Compare CMS staff focused on updates to the Hospice Quality Reporting Program (HQRP) as part of the September Open Door Forum. …

Hospice Provider Preview Reports and CAHPS Hospice Survey Update

PROVIDER PREVIEW REPORTS Hospice data in Care Compare will be refreshed in November.  Hospices can now access the Provider Preview Reports for this refresh via the Certification and Survey Provider Enhanced Reports (CASPER) application. Once released in CASPER, providers will have 30 days during which to review their quality measure results.  Although the actual “preview…

Hospice Quality Reporting Program Update

The hospice quality reporting program (HQRP) quarterly update has been recently posted, including a reminder that the HQRP annual payment update penalty for providers not compliant with calendar year 2022 submission requirements jumps from two percent to four percent.

In addition, there are updates related to public reporting, Q&A, and new HQRP resources among other updates. In addition to the quarterly update, there are a few items of note related to the HQRP.

  1. Hospices are reminded that the Hospice Visits in Last Days of Life (HVLDL) and the CAHPS Hospice Survey Star Rating will be posted to Care Compare this month. As reported previously, these measures were to be publicly reported in May of this year but were delayed due to an error in the provider preview reports.
  2. The HVLDL was formally endorsed by the National Quality Forum (NQF) at the end of July. NAHC and others submitted comments to the NQF about concerns with the HVLDL, primarily that it does not represent the care being provided to beneficiaries since it includes only RN and SW visits and does not include telehealth visits.  We included concerns in our comments to the NQF about the data used by the Centers for Medicare and Medicaid Services (CMS) in deciding which types of visits should be included in the measure. While NQF ultimately endorsed the measure it recommended that CMS continue to develop the measure. Comments submitted that highlighted the concerns about the measure were an important component to this recommendation. NAHC also shared concerns about the HVLDL in the response to the FY2023 hospice proposed wage index and payment update and quality reporting program update rule.  CMS acknowledged the comments in the final rule and indicated it is considering these comments.
  3. Notification to non-compliant hospice providers based on their CY 2021 quality data impacting FY 2023 payments was disseminated in July. Providers can find the notifications in their CASPER folders and should receive a notification from their Medicare Administrative Contractor (MAC). Providers have thirty (30) days from the date on the notification of non-compliance to submit a request for reconsideration. More information on the timeline for this process can be found in the quarterly update and on the CMS HQRP Reconsideration Requests webpage.
  4. Hospices are reminded that the Hospice quality reporting data submitted in CY 2022 data, starting on January 1, 2022 impacts FY 2024 payments. Beginning with FY 2024, the APU penalty doubles, going from 2% to 4%, for hospices not meeting the HQRP requirements. To ensure hospices achieve the full APU, be certain to meet the quality reporting requirements for data submission in CY 2022:
Annual Payment Update HIS CAHPS
FY2024 Submit at least 90 percent of all HIS records within 30 days of the event date (patient’s admission or discharge) for patient admissions/discharges occurring 1/1/22 – 12/31/22. Ongoing monthly participation in the Hospice CAHPS survey 1/1/2022 – 12/31/2022

Most hospices that receive the APU penalty do so because of noncompliance with the Hospice Item Set (HIS) submission requirements.  This frequently occurs during changes in EHR systems and changes in staffing so hospices should be sure to confirm submission of the HIS timely by downloading the Final Validation Reports.  This report identifies HIS submissions received by CMS, and this receipt must occur in order for the hospice to receive “credit” for having submitted the HIS.

5. CMS has added some new resources for the HQRP which are below. CMS also indicated that it plans to host a Forum in September, but no dates have been provided yet.  Stay tuned to NAHC Report for more information as it becomes available.

A) Hospice Care Index (HCI) Explanatory Video: CMS has developed a new video resource explaining the purpose and design of the claims-based HCI quality measure. This video provides an overview of the new HCI claims-based measure, which combines several quality indicators into a single index score.

B) HQRP Explanatory Video: The video introduces the purpose of the HQRP, how data is collected for use in HQRP, and the quality measures included in HQRP.

Hospice Quality Reporting Program Update

The hospice quality reporting program (HQRP) quarterly update has been recently posted, including a reminder that the HQRP annual payment update penalty for providers not compliant with calendar year 2022 submission requirements jumps from two percent to four percent. In addition, there are updates related to public reporting, Q&A, and new HQRP resources among other…

Preview Reports and Star Rating Preview Reports for the October 2022 Refresh

For this refresh, Home Health (HH) Outcome and Assessment Information Set (OASIS) will be based on the standard number of quarters. Due to the COVID-19 reporting exceptions, the claims-based measures have been calculated excluding Q1 and Q2 2020 data from measure calculations. The HH QRP claims-based quality measures will not be refreshed for the October…

Hospice Care Index Technical Report Released

Abt Associates submitted the Hospice Care Index Technical Report to the Centers for Medicare & Medicaid Services. The report provides context and descriptive analyses for the Hospice Care Index (HCI). The HCI is a new quality measure for the Hospice Quality Reporting Program (HQRP) that will be publicly reported on Care Compare in August 2022. The measure was added to the HQRP in 2022 and is a single measure comprising ten indicators calculated from Medicare claims.

The ten claims-based indicators comprising the HCI are shown below.

Hospices have had concerns about the indicators seemingly focusing more on program integrity issues than quality of care.  CMS repeats in this report what it has said in the past – that the HCI provides a broad overview of hospice care quality. CMS further explains that each indicator in the index represents a particular care practice of concern, as identified by CMS’ information gathering activities and that the HCI was developed to fill several identified information gaps:

  • Provision of Higher Levels of Hospice Services:

CMS requires hospices be able to provide both continuous home care (CHC) and general inpatient care (GIP) to manage more intense symptom crises. However, around a quarter of all programs do not provide GIP services each year, and it is unclear if patients in crisis received appropriate care (a similar concern exists regarding the CHC level of care.)

  • Visits by Professional Hospice Staff:

Medicare Conditions of Participation (CoPs) require the hospice interdisciplinary team to ensure on-going patient and caregiver assessment, plan of care implementation, and 24/7 availability of hospice services. Additionally, the end of life is typically the period in the terminal illness trajectory with the highest symptom burden, necessitating close care and attention from hospice staff.

  • Patterns of Hospice Live Discharges and Transitions:

Providers are expected to have some live discharges, but rates that are substantially higher than other hospices could signal a potential problem such as poor care quality, poor program integrity, failing to meet patients’ or families’ needs, or admitting patients who do not meet  eligibility criteria. Atypical transition patterns suggest problems in hospices’ care processes, advance care planning to prevent hospitalizations, or discharge processes. Revocations may also be related to business practices or quality of care.

  • Medicare Spending:

CMS currently reports per-beneficiary spending estimates for other care settings. Half of hospice expenditures are for patients that have had at least 180 or more days on hospice, raising concerns that some programs do not appropriately discharge ineligible patients, enroll patients with longer predicted lengths of stay in hospice, or inappropriately bill for highlevel, higher-rate services such as GIP.

Per CMS, the indicators represent a hospice’s ability to address patients’ needs, best practices hospices should observe, and/or care outcomes that matter to consumers. Each HCI indicator has its own numerator, denominator, and resulting indicator score. A hospice earns a point each time it meets the threshold for an indicator. Hospices’ HCI scores are calculated as the total number of earned points across the ten indicators and can range from a perfect 10 to a 0.  Index Earned Point Criteria were set based on CMS’ statistical analysis of national hospice performance to ensure meaningful distinction between hospices. It is only the Index score that will be publicly reported in August, but hospices can see their performance compared to norms in the Provider Preview Reports available in their CASPER folders.

For this recently released technical report, 100 percent of Medicare Fee-For-Service (FFS) claims data from eight quarters across calendar years 2019 through 2021 were used by CMS to calculate scores for the ten indicators and the overall index to assess the HCI against National Quality Forum (NQF) performance standards for validity and variability. Nationally, the average HCI score is 8.8, with 37.9 percent of hospices receiving a score of 10. No hospice scored a two or below. The report states that the  range of scores indicates sufficient potential to differentiate hospice performance which is one of CMS’ goals for quality measures.

In general, HCI scores were higher on average among larger hospices, older hospices, non-profit hospices, and facility-based hospices. Scores were also higher on average among hospices in northern states. There was not a strong difference in average HCI scores between hospices in urban and rural areas. CMS found a correlation between a higher HCI score and a higher percentage of caregivers reporting that they would recommend the hospice (through the CAHPS® Hospice Survey).  The report provides details of the correlation between indicators, the likelihood of HCI indicators for which hospices failed to achieve points and the HCI indicators’ relationships to CAHPS® Hospice outcome scores.  The report also provides details about the design and structure of the HCI including the rationale for the indicators and a scoring explanation.

Hospice Care Index Technical Report Released

Abt Associates submitted the Hospice Care Index Technical Report to the Centers for Medicare & Medicaid Services. The report provides context and descriptive analyses for the Hospice Care Index (HCI). The HCI is a new quality measure for the Hospice Quality Reporting Program (HQRP) that will be publicly reported on Care Compare in August 2022.…

Summary of the CMS Open Door Forum on June 29

During the Centers for Medicare and Medicaid Services (CMS) Home Health, Hospice, and DME Open Door Forum on June 29, 2022, CMS reminded hospices that the August refresh of Care Compare will include the two new claims-based measures – Hospice Visits in Last Days of Life and Hospice Care Index.  These measures were slated to be publicly reported with the May refresh of Care Compare but this was pushed back to August due to errors in the Provider Preview Reports for these measures issued in March.  Therefore, hospices are to disregard the preview reports for March.  Corrected preview reports are available now.

The reconsideration period for the FY2023 annual payment update (APU) hospice quality reporting program (HQRP) requirements is coming up.  Hospice providers will receive notification from their Medicare Administrative Contractor (MAC) if they are subject to the APU penalty, and they will also receive notification in their CASPER folder.

Several new resources are scheduled to be posted to the HQRP website soon.  These include the latest quarterly communication as well as new video resources that provide an overview of HQRP and an explanation of the HCI measure.  CMS is also planning to release a technical report on the HCI.  Stay tuned to NAHC Report for more information as these items become available.

There was some concern expressed by hospice participants in the ODF that the Care Compare website currently reflects that data for the HCI and HVLDL is suppressed upon request from the agency. This is not accurate as CMS suppressed the data due to an error in the preview reports, as stated above. CMS indicated that there is an additional update to the footnotes that will be pushed out soon and should provide some additional clarity on this situation for the public.

Summary of the CMS Open Door Forum on June 29

The Centers for Medicare and Medicaid Services (CMS) held a Home Health, Hospice, and DME Open Door Forum on June 29, 2022. The summary of the Forum applicable to home health and hospice providers is below. HOME HEALTH CMS provided a high-level summary of the CY 2023 Home Health PPS Rule.  (See the NAHC Report…

NEW Hospice Provider Preview Reports

Last month, the Centers for Medicare & Medicaid Services (CMS) announced that the Hospice Visits in the Last Days of Life (HVLDL) and the Hospice Care Index (HCI) claims-based measures were not publicly displayed as planned in the May 2022 refresh. NAHC reached out to CMS about this and learned that there were technical errors in the data calculation, which were discovered well after the Preview Reports for these measures were released to hospices in March.

CMS is mandated to give providers a full 30 days to review the Preview Reports.  Because of this, there was not time to re-release Preview Reports prior to the planned May 2022 refresh.  Hospices should disregard the Preview Reports released in March for the HVLDL and HCI.

CMS is targeting the August 2022 refresh for the inaugural display of these quality measures and announced that new Provider Preview Reports for the HVLDL and HCI are now available in hospice’s CASPER (Certification and Survey Provider Enhanced Reports) folder. 

Hospices utilized data from the incorrect scores in the Preview Reports to plan for performance improvement and they may have to adjust their priorities and plans now that the new Preview Reports are available.

The recently available provider Preview Reports also contain the Preview Reports for other publicly reported measures that will be updated in the August 2022 Care Compare refresh.  These include the CAHPS Hospice Star Rating and the HIS Comprehensive Assessment measure.

Once released in CASPER, providers will have 30 days during which to review their quality measure results.  Although the actual “preview period” is 30 days, the reports will continue to be available for another 30 days, or a total of 60 days. The preview period for the latest Provider Preview Report lasts from May 25, 2022 to June 27, 2022.

CMS encourages providers to download and save their Hospice Provider Preview Reports for future reference, as they will no longer be available in CASPER after this 60-day period.