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.
