Hospice Proposed Rule Listening Session – Health Equity RFI and Payment

  • REGISTER NOW for these listening sessions!
  • Friday, May 20

On March 30, the Centers for Medicare & Medicaid Services (CMS) issued a proposed FY2023 hospice rule containing a Request for Information (RFI) on health equity, a proposed cap on wage index losses from year to year and providing guidance on projected payment rates. 

NAHC invites you to participate in one or more of the following listening sessions to provide input on the RFI and proposals. This input will help inform comments NAHC submits at the end of the month.

The RFI has two components:

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Hospice Proposed Rule Listening Sessions – Health Equity RFI and Payment

REGISTER NOW for these listening sessions! Tuesday, May 17 Wednesday, May 18 Friday, May 20 On March 30, the Centers for Medicare & Medicaid Services (CMS) issued a proposed FY2023 hospice rule containing a Request for Information (RFI) on health equity, a proposed cap on wage index losses from year to year and providing guidance on…

Hospice Proposed Rule Listening Sessions – Health Equity RFI and Payment

  • REGISTER NOW for these listening sessions!
  • Thursday, May 12
  • Tuesday, May 17
  • Wednesday, May 18
  • Friday, May 20

On March 30, the Centers for Medicare & Medicaid Services (CMS) issued a proposed FY2023 hospice rule containing a Request for Information (RFI) on health equity, a proposed cap on wage index losses from year to year and providing guidance on projected payment rates. 

NAHC invites you to participate in one or more of the following listening sessions to provide input on the RFI and proposals. This input will help inform comments NAHC submits at the end of the month.

The RFI has two components:

  1. CMS is soliciting public comment on the following questions:
    • What efforts does your hospice employ to recruit staff, volunteers, and board members from diverse populations to represent and serve underserved populations? How does your hospice attempt to bridge any cultural gaps between your personnel and beneficiaries/clients? How does your hospice measure whether this has an impact on health equity?
    • How does your hospice currently identify barriers to access in your community or service area? What are barriers to collecting data related to disparities, social determinants of health, and equity? What steps does your hospice take to address these barriers?
    • How does your hospice collect self-reported data such as race/ethnicity, veteran status, socioeconomic status, housing, food security, access to interpreter services, caregiving status, and marital status used to inform its health equity initiatives?
    • How is your hospice using qualitative data collection and analysis methods to measure the impact of its health equity initiatives?
  2. CMS is seeking information on publicly reporting a composite structural health equity quality measure; displaying descriptive information on Care Compare from the data hospices provide to support health equity measures; and the impact of the domains and quality measure concepts on organizational culture change.
    • Domain 1: Hospice commitment to reducing disparities is strengthened when equity is a key organizational priority. Candidate domain 1 could be satisfied when a hospice submits data on their actions regarding the role of health equity and community engagement in their strategic plan. Hospices could self-report data in the reporting year about their actions in each of the following areas, and submission of data for all elements could be required to qualify for the measure numerator
      • Hospice attests whether its strategic plan includes approaches to address health equity in the reporting year.
      • Hospice reports community engagement and key stakeholder activities in the reporting year.
      • Hospice reports on any attempts to measure input from patients and caregivers about care disparities they may experience and recommendations or suggestions
    • Domain 2: Training board members, leaders, staff and volunteers in culturally and linguistically appropriate services (CLAS)27, health equity, and implicit bias is an important step hospices take to provide quality care to diverse populations. Candidate domain 2 could focus on hospices’ diversity, equity, inclusion and CLAS training for board members, employed staff, and volunteers by capturing the following self-reported actions in the reporting year. Submission of relevant data for all elements could be required to qualify for the measure numerator.
      • Hospice attests whether employed staff were trained in CLAS and culturally sensitive care mindful of social determinants of health (SDOH) in the reporting year. Example data include specific training programs or training requirements for staff.
      • Hospice attests whether it provided resources to staff and volunteers about health equity, SDOH, and equity initiatives in the reporting year. Examples include the materials provided, webinars, or learning opportunities.
    • Domain 3: Leaders and staff could improve their capacity to address disparities by demonstrating routine and thorough attention to equity and setting an organizational culture of equity. This candidate domain could capture activities related to organizational inclusion initiatives and capacity to promote health equity. Examples of equity-focused factors include proficiency in languages other than English, experience working with populations in the service area, experience working on health equity issues, and experience working with individuals with disabilities. Submission of relevant data for all elements could be required to qualify for the measure numerator.
      • Hospice attests whether equity-focused factors were included in the hiring of hospice senior leadership, including chief executives and board of trustees, in the previous reporting year.
      • Hospice attests whether equity-focused factors were included in the hiring of hospice senior leadership, including chief executives and board of trustees, is more reflective of the services area patient than in the previous reporting year.
      • Hospice attests whether equity-focused factors were included in the hiring of direct patient care staff (for example, RNs, medical social workers, aides, volunteers, chaplains, or therapists) in the previous reporting year.
      • Hospice attests whether equity focused factors were included in the hiring of indirect care or support staff (for example. administrative, clerical, or human resources) in the previous reporting year.

REGISTER NOW for these listening sessions!

Hospice Proposed Rule Listening Sessions – Health Equity RFI and Payment

REGISTER NOW for these listening sessions! Thursday, May 12 Tuesday, May 17 Wednesday, May 18 Friday, May 20 On March 30, the Centers for Medicare & Medicaid Services (CMS) issued a proposed FY2023 hospice rule containing a Request for Information (RFI) on health equity, a proposed cap on wage index losses from year to year…

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Hospice Quality Reporting Update for February 2, 2022

  • CAHPS Star Rating
  • CASPER toolkit
  • HIS, HCI, HVLDL

A CAHPS Hospice Survey Star Rating will be added to Care Compare for hospices with the August 2022 refresh. How the star rating is calculated, what will be publicly reported, and information about the current “dry run” and provider preview information are part of the overview.  Stay tuned to NAHC Report for member resources on the CAHPS Hospice Survey Star Rating.

The Centers for Medicare & Medicaid Services (CMS) conducted an overview of the star rating in a webinar on December 16, 2021 and the materials from the webinar – slide deck, transcript, and recording — are now available here.

CMS also updated and rebranded a provider toolkit for hospices, Getting Started with Hospice CASPER Quality Measure Reports: February 2022. The toolkit is to assist hospice providers in understanding and using the CASPER Quality Measure (QM) Reports that now include claims-based measures.  There are two reports:

  • The Hospice-Level QM Report includes the HIS Comprehensive Assessment at Admission (NQF #3235), HCI, and HVLDL measure scores.
  • The Hospice Patient-Level QM Report identifies each patient with a qualifying HIS record used to calculate the hospice-level quality measure values for a select period.

The reports are detailed, and hospices may be especially interested in the Hospice Care Index (HCI) and Hospice Visits in Last Days of Life (HVLDL) information.

NAHC conducted a webinar on these measures in December where we reviewed the most frequently asked questions about the HVLDL and explained the HCI – each of its ten indicators, calculation of the index score, and expected performance for each of the indicators and the index. Information from the webinar and from a hospice’s QM reports are helpful for performance improvement. The recording of the webinar is available here.

Hospice Quality Reporting Update for February 2, 2022

CAHPS Star Rating CASPER toolkit HIS, HCI, HVLDL A CAHPS Hospice Survey Star Rating will be added to Care Compare for hospices with the August 2022 refresh. How the star rating is calculated, what will be publicly reported, and information about the current “dry run” and provider preview information are part of the overview.  Stay tuned…

Hospice Star Rating, Updated HCI Provider Preview Reports, and HQRP Tip Sheets

A Centers for Medicare & Medicaid Services’ (CMS) webinar on the CAHPS hospice star rating on December 16, 2021 revealed additional detail about the rating, which will be publicly reported on Care Compare beginning in August 2022. CMS is calling this star rating the “Family Caregiver Survey Rating Summary Star” and it will range from one star (worst) to five stars (best).

CMS will calculate nine CAHPS Hospice Star Ratings: one for each of the eight publicly reported CAHPS Hospice measures and a Family Caregiver Survey Rating, which is a summary star rating that combines the star ratings of the eight family caregiver experience measures. Only the CAHPS Hospice Summary Star Rating will be publicly reported on Care Compare and only those hospices with 75 or more completed surveys over the reporting period will have their star rating publicly reported. The rating will be updated every other quarter (every 6 months). CMS is using the February 2022 and May 2022 Care Compare refresh period as a “dry run”. This allows hospices to see their star ratings and what the summary star rating would be if it were to be posted on Care Compare.

Again, CMS will not post the Star Rating on Care Compare until August 2022. Hospices can see their first “dry run” ratings in their CMS Preview Report that became available in November 2021. This is an “on demand” report so it does not automatically appear in the CASPER folder. Hospices need to run the report from the “Hospice Quality Reporting Program” report category. The reporting period for the dry run is October 1, 2018 – December 31, 2019; July 1, 2020 – March 31, 2021. More information about how to access the Star Rating Preview Report is found in the Hospice Quality Reporting Measure Specifications User’s Guide.

During the webinar, CMS explained the calculation of the star rating, which is similar to calculations CMS uses in other quality reporting programs. Top-box scores, the proportion of respondents who gave the most favorable response(s) for each of the CAHPS Hospice Survey measures that are publicly reported, are used and adjusted for the case mix of the hospice and mode of survey administration. CMS intended with the calculation to have maximal differentiation between the star categories and to have minimal differentiation of hospices within the star category making the star rating more meaningful. Detailed information regarding the calculation can be found in the CAHPS Star Rating Technical Notes.

A little more than 2000 hospices met the eligibility criteria to be assigned a star rating for the dry run period. This is not an overwhelming majority of hospices so it is possible there are pockets where only some of the hospices will have a publicly reported Star Rating which may make comparison among hospices confusing. Approximately 90 percent of Medicare beneficiaries enrolled in hospice in 2020 were enrolled in a hospice that does have a Star Rating during the dry run.

The slides and recording of the December 16 webinar will also be available soon on the CMS Hospice Quality Reporting webpage. Additionally, NAHC is developing a resource for providers which will be available at the beginning of 2022.

HCI UPDATE
Due to an issue identified with the national averages and percentile calculations for the Hospice Care Index (HCI) measure, CMS revised the data for the HCI Preview Reports. Hospices are able to access these revised reports via the Hospice Quality Reporting Program category in their CASPER folders now.

CMS is targeting the May 2022 refresh for the inaugural public display of the HCI and Hospice Visits in the Last Days of Life (HVLDL) claims-based measures. The eight quarters of claims data used to calculate these measures for a May 2022 refresh would include Q2 2019–Q4 2019 and Q3 2020–Q3 2021. CMS is also planning to provide annual updates to the claims-based measures in November 2022 and each following November refresh. Learn more about HCI and HVLDL in the Q&A on Claims-Based Measures downloadable (PDF) located on the Background and Announcements webpage.

HQRP TIP SHEETS
CMS updated the Hospice Quality Reporting Program (HQRP) resources on December 16 by posting two new Tip Sheets

Second Edition HQRP Public Reporting Tip Sheet
HQRP Compliance Tip Sheet_ FY 2022 and Future Years​
The Second Edition HQRP Public Reporting Tip Sheet explains how CMS will handle the impact of the temporary exemption of quality reporting that occurred due to the COVID-19 Public Health Emergency (PHE) in the HQRP going forward and incorporates the changes to the HQRP from the FY 2022 hospice final rule. The HQRP Compliance Tip Sheet_FY 2022 and Future Years provides information on the HQRP, compliance requirements and how to track compliance.