The Centers for Medicare & Medicaid Services recently posted the Hospice Outreach Email for June and it contains reminders and updates on the various Medicare hospice quality reporting program (HQRP) activities. There are two reminders hospices should take note of.
- Upcoming Reconsideration Period for the Fiscal Year (FY) 2023 HQRP
Data submitted in 2021 impacts the FY 2023 annual payment update (APU). If your hospice did not meet the reporting requirements in CY 2021 and will be subject to the FY 2023 APU penalty of 2%, the Centers for Medicare & Medicaid Services (CMS) will notify you in two ways:
- A notification from your Medicare Administrative Contractor (MAC) and
- A notification in your facility’s Certification and Survey Provider Enhanced Reports (CASPER) folder.
The notifications will be distributed on July 12, 2022 and will include instructions for submitting a reconsideration. There is a 30-day timeframe for filing the reconsideration request. For more information on your right to request a reconsideration and the CMS reconsideration process, please visit the Hospice Reconsideration Requests webpage.
- FY 2024 Hospice Quality Reporting Reminder
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.
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 
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:
