NAHC Urges CMS to Collect Data on Technology-based and Chaplain Visits

Prior to the COVID-19 Public Health Emergency (PHE) many hospice providers had significant success with use of technology-based visits; however, there were a number of hospices that did not utilize technologies to their fullest extent because they believed they were required to provide all visits in-person. Early in the PHE, the Centers for Medicare & Medicaid Services (CMS) communicated that hospices are permitted to use telecommunications technologies to deliver hospice visits provided that such visits and technologies are specified by the Interdisciplinary Team (IDT) on the plan of care and that the goals of care (as outlined) are met.

In response to CMS’ clarification, hospice providers throughout the nation began to utilize technology more broadly in hospice care delivery, and found that, when used appropriately, this mode of care can provide substantial benefits to patients, family members, and hospice staff. However, CMS instructed hospices to not report these visits on hospice claims, which raised significant concern that CMS would not have accurate information on the full scope of services being provided to hospice patients, and that CMS and others would have no way of determining the impact that use of telecommunications technologies has on the quality of hospice care. The National Association for Home Care & Hospice (NAHC) has communicated to CMS a number of times since the start of the PHE that data on hospice “virtual” visits should be collected.

On a related matter, CMS has never required collection of data on chaplain visits on hospice claims, although previously, when the Hospice Item Set (HIS) data was directly submitted by hospice organizations and CMS gathered date for the Hospice Visits When Death is Imminent (HVDII) measure pair, the number of chaplain visits delivered during the last seven days of life was collected. The HVDII measure pair has been replaced with a claims-based measure (Hospice Visits in the Last Days of Life), which does not assess chaplain visits. As chaplains are essential members of the hospice IDT and the provision of chaplain services is a distinguishing element of the hospice benefit, NAHC and others have strongly urged CMS to collect data on chaplain visits on claims.

During the January 2022 meeting of the Medicare Payment Advisory Commission (MedPAC), the Commission approved a recommendation that the Secretary of Health & Human Services collect data on telehealth visits going forward as long as the agency permits telehealth visits in hospice. In putting forth the recommendation for the MedPAC March 2022 Report to Congress, Commission staff noted that, “Requiring hospices to report telehealth visits would increase the program’s ability to monitor beneficiary access to care.”  MedPAC’s recent action prompted the national hospice associations  (NAHC, NHPCO, LeadingAge, and NPHI) to join together in a letter to CMS Administrator Chiquita Brooks-LaSure urging that CMS:

  • Implement a modifier or HCPCS code and create a field on the hospice claim for telehealth visits from any discipline, to more accurately represent the full range of visits that hospices provide
  • Take the necessary steps to establish a HCPCS code specifically for chaplains in hospice and require reporting of chaplain visits on claims

The full letter to Administrator Brooks-LaSure is available HERE.  NAHC will provide updates on this and related issues in future issues of NAHC Report.

NAHC Urges CMS to Collect Data on Technology-based and Chaplain Visits

Prior to the COVID-19 Public Health Emergency (PHE) many hospice providers had significant success with use of technology-based visits; however, there were a number of hospices that did not utilize technologies to their fullest extent because they believed they were required to provide all visits in-person. Early in the PHE, the Centers for Medicare &…

CMS Launches New Tool to Compare Nursing Home Vaccination Rates

Hospice organizations provide a significant level of services to nursing facility patients and have experienced numerous challenges throughout the COVID-19 Public Health Emergency delivering care to nursing home patients. Therefore, NAHC believes hospice providers might be interested in recent action taken by the Centers for Medicare & Medicaid Services (CMS) to provide public access to…

56th Anniversary of Medicare and Medicaid

On July 30, 1965, President Lyndon B. Johnson signed into law legislation that established Medicare and Medicaid. For 56 years since, these programs have helped to protect the health and well-being of millions of Americans throughout all of life’s key moments. HHS Secretary Xavier Becerra and CMS Administrator Chiquita Brooks-LaSure released the following statements to…

Biden’s Choice for CMS Admin Confirmed

The United States Senate confirmed President Joe Biden’s choice to be the next administrator of the Centers for Medicare & Medicaid Services (CMS) on a mostly party-line vote of 55-44. Republicans Roy Blunt (MO), Richard Burr (NC),  Susan Collins (ME), Jerry Moran (KS), and Lisa Murkowski (AK) voted with the Democrats to confirm.

Ms. Brooks-LaSure becomes the first African-American woman to run CMS, the largest component of the Department of Health & Human Services (HHS), with ten offices around the country, more than 6000 employees, and over $1 trillion in annual expenditures.

CMS has regulatory oversight of most health care providers in the country and it administers Medicare, Medicaid, the Affordable Care Act (ACA) marketplaces, and the Children’s Health Insurance Program (CHIP), covering at least 145 million people around the country.

“Chiquita Brooks-LaSure brings solid experience to a very difficult job,” said NAHC President Bill Dombi in reaction to her confirmation as CMS Administrator. “Over the years, she has demonstrated a high degree of capability and the versatility to handle the wide range on matters that occur in Medicare and Medicaid. We look forward to working with her to expand access to home and community-based services and make the home the center of health care.”

Ms. Brooks-LaSure graduated from Princeton University in 1996 and earned a Masters of Public Policy from Georgetown University in 1999, before beginning her career as aprogram examiner and Medicaid analyst at the Office of Mangagement & Budget (OMB). She has worked for the Democratic staff on the Ways & Means Committee in the House of Representatives, working on issues like the ACA and the Medicare Improvements for Patients and Providers Act (MIPPA). Ms. Brooks-LaSure moved on to CMS, where she worked in the Center for Consumer Information and Insurance Oversight (CCCIIO), leading ACA implementation on insurance reform. Like many other Biden appointees, Ms. Brooks-LaSure is a veteran of the Obama administration.

Ms. Brooks-LaSure has stayed very busy since leaving government and she is currently the Manging Director of Manatt Health, consulting on health care financing. She serves on the board of directors of FAIRHealth, a non-profit working for health care cost transparency, and she has been a consultant to The Commonwealth Fund, that works for improved access, efficiency, and quality in health care, particularly for the poor and uninsured. Virginia Governor Ralph Northam named Ms. Brooks-LaSure to the Virginia Health Benefits Exchange Advisory Council last September.

Crucially, Ms. Brooks-LaSure ran the HHS agency review team during the Biden transition period, so her familiarity with the administration’s health care plans is complete.

Ms. Brooks-LaSure testified before the House Ways & Means Committee on “Pathways to Universal Health Coverage,” defending the ACA record, calling for more Medicaid expansion, and creating a Medicare buy-in option, particularly for people just shy of the age qualifications and above the ACA subsidy level. Ms. Brooks-LaSure spoke favorably of such a buy-in, stressing that it could expand coverage and still keep the current very popular Medicare program intact.

Ms. Brooks-LaSure worked on a Medicare buy-in presentation to the state of New Mexico in 2018 and, authored an issue brief with her colleagues at Manatt Health on the subject of Medicare buy-in. The brief also covered Medicaid buy-ins, calling it “chief among the emerging state-based solutions.”

During the presidential campaign, the Biden campaign promoted creating an option “like Medicare,” but not exactly the sort of Medicare buy-in Ms. Brooks-LaSure favored in her 2019 testimony. However, her proposal is not unlike H.R. 1346, the Medicare Buy-In and Health Care Stabilization Act of 2019 in the previous Congress. Fifty-one Democrats co-sponsored that bill, including several members of the responsible committee.

In her 2019 testiony to Congress, Ms. Brooks-LaSure seemed open to a public option in health care, suggesting it could lower premiums and increase affordability and access to quality health insurance.

Ms. Brooks-LaSure’s career has been marked by a determination to make health care more accessible and affordable, with a particular focus on the poor and women’s health. She has been one of the leading Democratic thought leaders on these subjects and, thus, her likely appointment to CMS is not a surprise.

Biden’s Choice for CMS Admin Confirmed

The United States Senate confirmed President Joe Biden’s choice to be the next administrator of the Centers for Medicare & Medicaid Services (CMS) on a mostly party-line vote of 55-44. Republicans Roy Blunt (MO), Richard Burr (NC),  Susan Collins (ME), Jerry Moran (KS), and Lisa Murkowski (AK) voted with the Democrats to confirm. Ms. Brooks-LaSure becomes…

Reports: Biden to Nominate Chiquita Brooks-LaSure as CMS Admin

According to reports, President Joe Biden will select Chiquita Brooks-LaSure to be the next administrator of the Centers for Medicare & Medicaid Services (CMS), the largest component of the Department of Health & Human Services (HHS), with ten offices around the country, more than 6000 employees, and over $1 trillion in annual expenditures. CMS has…