NAHC to Congress: Extend the Acute Hospital Care at Home Waiver Program

The National Association for Home Care & Hospice and a group of likeminded organizations have written to leaders in the Senate and House of Representatives to urge Congress to prioritize extending the Acute Hospital Care at Home (AHCAH) waiver program as part of the next government funding package on February 18th. Many seniors needing acute-level…

Home Health Quality Reporting Update

The January 2022 quarterly refresh for the Home Health Quality Reporting Program is now available on Care Compare. For this refresh, Home Health (HH) Outcome and Assessment Information Set (OASIS) measure scores are based on three quarters of OASIS assessment data, due to the temporary exception to the HH Quality Reporting Program (QRP) data submission requirements in…

Provider Relief Fund Round 2 Reporting Now Open

  • Submit Reports by March 31, 2022

The Health Resources and Services Administration (HRSA) recently opened the Provider Relief Fund (PRF) reporting portal for providers to begin entering data to submit their second period PRF reports. Providers who received one or more General and/or Targeted PRF payments exceeding $10,000, in the aggregate, from July 1, 2020 to December 31, 2020 must report on their use of funds in Reporting Period 2.

Second period PRF reports will cover PRF payments received July 1, 2020 – December 31, 2020, which include Phase 2 and Phase 3 general distributions. The deadline to use funds for Payment Period 2 was December 31, 2021.

The deadline to submit the second period report is March 31, 2022.

HRSA has added a number of new resources to the PRF reporting website specific to the second reporting period.

Key Provider Relief Fund Resources

HRSA webinar on Period 2:

Providers who were required to report in Reporting Period 1, but did not report are out of compliance with the PRF Terms and Conditions and must return Payment Period 1 PRF payment(s) to HRSA (if you are out of compliance, see HRSA’s resource, Reporting Non-Compliance Fact Sheet). Non-compliant providers will be excluded from receiving and/or retaining future PRF payments – including any applicable Phase 4 payments. HRSA will seek repayment on all PRF payments received between April 10, 2020 – June 30, 2020 and not reported on during Reporting Period 1.

NAHC will continue to monitor all PRF reporting updates and provide timely updates to our members.

MedPAC Recommends 20 Percent Cut to Hospice Aggregate Cap

  • Payment Freeze, Aggregate Cap and Telehealth Visit Reporting Highlighted

Late last week, the Medicare Payment Advisory Commission (MedPAC), an advisory body to the U.S. Congress, verbally approved the following recommendations:

  • For fiscal year (FY) 2023, the Congress should eliminate the update to the 2022 Medicare base payment rates for hospice and wage adjust and reduce the hospice aggregate cap by 20 percent; and
  • The Secretary of Health and Human Services should require that hospices report telehealth services on Medicare claims.

A formal vote will be taken at a January 2022 meeting.

On an annual basis, MedPAC reviews draft policy recommendations for inclusion in its annual Report to Congress: Medicare Payment Policy issued each March. The Commissioners met to discuss a wide array of preliminary recommendations that included discussion of hospice payment and related issues.

The first recommendation is a repeat of recommendations from the previous two reports; MedPAC staff indicated that based on existing analysis they do not believe these changes would negatively impact access to hospice care or willingness or ability of hospice providers to care for beneficiaries.

The second recommendation regarding telehealth services was motivated by the expanded use of telecommunications-based visits during the public health emergency (PHE) and the need to know the extent to which telehealth visits are being conducted and access to care during the PHE.

The National Association for Home Care & Hospice (NAHC) has strongly urged the Centers for Medicare & Medicaid Services (CMS) to begin collection of data related to telecommunications-based visits to ensure more complete knowledge of services that are being provided as part of the hospice benefit.

In arriving at these recommendations MedPAC examined a great deal of data regarding the Medicare hospice program that provides insights into existing hospice payment adequacy as viewed through four separate lenses:

  • Beneficiaries’ access to care, including the supply of providers; use, length of stay, and visits; and marginal profit
  • Quality of care, including findings of the CAHPS Hospice Survey and visits at the end of life – while quality data were not available due to the PHE, there was a slight improvement in the share of patients receiving at least one visit from a nurse or other clinician in last three days of life in 2019. MedPAC also indicated that while in-person visits declined during 2020 that does not necessarily reflect a reduction in quality but more likely was due to the PHE
  • Hospices’ access to capital, including provider entry and financial reports and mergers and acquisition activity – continued growth in the number of for-profit providers (7 percent increase) and continued favorable perspectives on the sector by investors indicates positive access to capital
  • Medicare payments and hospices’ costs, including overall Medicare margins in 2019 and the projected overall Medicare hospice margin in 2022 – the 2019 Medicare hospice margin was 13.4 percent, and four of five provider quintiles average margins of over 10 percent. Non-profit hospices and provider-based hospices generally experience lower margins.

Following are some key data provided during the meeting:

  • Medicare hospice outlays grew to $22.4 Billion in 2020;
  • In 2020, over 5,000 providers served over 1.7 million beneficiaries;
  • The number of hospice providers grew by 4.5 percent during 2020, largely driven by the growth in for-profit hospice providers;
  • Hospice deaths in 2020 increased by 18 percent;
  • The number of decedents using hospice increased by 9 percent;
  • The share of decedents using hospice declined to 47.8 percent in 2020 (from 51.6 percent in 2019;
  • Total number of hospice users increased by 6.6 percent between 2019 and 2020;
  • The number of hospice days increased by 4.9 percent in 2020;
  • During 2020 more hospice patients were cared for at home, in assisted living facilities, and in hospitals, while fewer were cared for in nursing facilities and hospice facilities;
  • Average length of stay increased from 92.5 days in 2019 to 97.0 days in 2020, while the median length of stay remained stable at 18 days;
  • Average in-person visits per week decreased from 4.3 visits in 2019 to 3.5 in 2020, with aide visits experiencing the largest decline, although nursing visits also declined (likely offset to some extent by use of telehealth visits);
  • Marginal profit in 2019 was 17 percent; and
  • During 2019, 19 percent of hospices exceeded the aggregate cap (margin prior to recoupment was 22.5 percent and 10 percent afterward).

While time for general discussion was limited, Commissioners expressed a great deal of interest in this sector, including the status of the Medicare Advantage VBID Hospice Component Model (a CMS demonstration model under which hospice is being covered as part of the MA benefit package), concerns about access to care in rural areas, concerns about the impact of the workforce shortage on hospice care, request for further exploration of live discharges in hospice care, and the degree to which the hospice population has changed and reflects a higher proportion of patients with cognitive disease.

A copy of the slides used during the staff presentation is available HERE.  In the coming days, a copy of the full transcript of the meeting will be posted HERE.

CMS Updated Quality Reporting in the Open Door Forum

The Centers for Medicare & Medicaid Services (CMS) provided some important quality updates in the Tuesday, December 14 Home Health, Hospice, and DME (Durable Medicare Equipment) Open Door Forum (ODF). What follows is a detailed summary of those updates from a NAHC staffer who monitored the call.

HOSPICE QUALITY REPORTING PROGRAM UPDATES

CMS reminded hospices that the FY2024 annual payment update is based on the CY2022 data submissions.  Hospices must comply with the following HIS and Hospice CAHPS Survey participation requirements to avoid the APU penalty which increases to 4% in FY2024.

  • Submit at least 90% of HIS records within the 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 CAHPS Hospice Survey 1/1/22 – 12/31/22

CMS also reminded hospices that it recognizes that there are instances where an extraordinary or extenuating circumstance beyond the hospice’s control (e.g., natural disasters) may delay or prevent submission of required data, and hospices can submit requests for an extension or exemption within 90 days of the extraordinary circumstance event.  NAHC encourages hospices to review the HQRP webpage devoted to these instances for more information and to submit a request for an extension or exemption when warranted.  While the example CMS uses for such a circumstance is a natural disaster there are other circumstances that are out of the hospice’s control and impact its ability to submit quality data such as the current COVID pandemic.

Public reporting for hospices will resume with the February 2022 refresh on Care Compare. This refresh excludes Q1 and Q2 2020 data due to the Public Health Emergency (PHE) exemption of data submission requirements for these quarters.  So, CMS will use fewer quarters of data than usual for this refresh due to this exemption.  CMS plans to post a public reporting tip sheet later this week with more information about public reporting.

The Hospice Quality Reporting Program Quality Measure Specifications User’s Manual v1.00 is now available and reflects changes in the FY2022 hospice final rule, specifically the new Hospice Care Index (HCI) and Hospice Visits in Last Days of Life (HVLDL) measures. Updated documents related to the current measures including the Manual, a change table, and updated measures are available on the Current Measures webpage.

Materials from the HQRP webinar CMS held on October 19 are available in the Downloads section of the Provider & Stakeholder Engagement webpage.

Hospices should review documents available in the Downloads and Provider Toolkit sections of the Requirements & Best Practices webpage as there are updated provider resource documents available.

CMS Updated Quality Reporting in the Open Door Forum

The Centers for Medicare & Medicaid Services (CMS) provided some important quality updates in the Tuesday, December 14 Home Health, Hospice, and DME (Durable Medicare Equipment) Open Door Forum (ODF). What follows is a detailed summary of those updates from a NAHC staffer who monitored the call. HOME HEALTH QUALITY REPORTING PROGRAM UPDATES The reconsideration…

MedPAC Recommends 20 Percent Cut to Hospice Aggregate Cap

Payment Freeze, Aggregate Cap and Telehealth Visit Reporting Highlighted Late last week, the Medicare Payment Advisory Commission (MedPAC), an advisory body to the U.S. Congress, verbally approved the following recommendations, with a formal vote will be taken at a January meeting: For fiscal year (FY) 2023, the Congress should eliminate the update to the 2022 Medicare…

CMS Updates Hospice Aide Services Fact Sheet

The Enhancing RN Supervision of Hospice Aide Services MLN Fact Sheet has been updated with  information about frequency and documentation requirements of registered nurses’ (RN) supervisory visits. The content was streamlined but no substantive content changes were made. However, this is a good time for hospices to revisit the topic of aide supervision. Under the current…

U.S. Renews Public Health Emergency Again

On October 15, Secretary of Health & Human Services (HHS) Xavier Becerra renewed the Public Health Emergency (PHE) that has been in effect since January 27, 2020 due to the outbreak of the novel coronavirus COVID-19. As a result of the continued consequences of the Coronavirus Disease 2019 (COVID-19) pandemic, on this date and after consultation with…

CMS Releases Details of Two New Hospice Quality Reporting Measures

Register for the October 19 Hospice Quality Reporting Program Forum (See details below) Hospices have been anxiously awaiting additional information on two new Hospice Quality Reporting Program (HQRP) measures: Hospice Visits in Last Days of Life Hospice Care Index. These are claims-based measures that CMS has indicated will be publicly posted on Care Compare no…