June 3, 2024 Washington, DC — In comments filed on the Centers for Medicare and Medicaid Services’ (CMS) FY25 Hospice Prospective Payment System (PPS) proposed rule, LeadingAge, the association of nonprofit providers of aging services, including hospices, offered feedback on the proposed 2.6% increase in the wage index and rate update, the implementation of the Hospice Outcomes and Patient Evaluation (HOPE) tool, and the request for information (RFI) on the payment mechanism for high intensity palliative care services.
“On payment, while CMS has proposed an increase, the impact, unfortunately, will be insufficient in helping our members’ address financial needs,” said LeadingAge President and CEO Katie Smith Sloan. “The 2.6% bump, which is below last year’s final 3.1%, does not keep pace with inflation or address rising costs – from wages to supplies – incurred to serve beneficiaries. Our members’ budgets are simply already stretched. CMS must reconsider and instead finalize an increase equal to the fiscal increase for FY2024 and add adjustments for inflation”
Adding to those financial challenges, LeadingAge notes in its comments, is the impact hospice providers will feel from the now-final staffing mandate for nursing homes– which, by our calculations, will require nearly 30,000 additional full-time equivalent registered nurses (RNs) for nursing home providers alone.
“With a program workforce predominantly made up of nurses,” said Sloan, “the mandate will create intense competition between post acute care providers and hospitals. And, unlike many hospitals, hospices cannot offer large signing bonuses to attract more nurses. Without an increase in payment or even keeping up with inflation, hospices will not be able to retain their nursing staff, leading to lack of access for older adults and families.”
Other topics included in LeadingAge comments:
Payment mechanism for high intensity palliative care services: Lauding the continuing the conversation around this policy, which has the potential to increase access to the hospice benefit, LeadingAge supports a single payment made for a period of time while CMS engages in the robust process outlined in our comments to get at actual costs and develop a payment mechanism that takes into account ancillary costs, variation in therapies, more therapies, and that the course of treatment may vary with intent. Importantly, LeadingAge urges CMS to bring together a strong stakeholder advisory process that would likely include a technical expert panel (TEP) to talk about types of therapies and the intricacies of coverage. LeadingAge does ask for more information regarding how CMS will pay for these proposals given that changes to hospice payment must be budget neutral.
Implementation timeline for the HOPE tool: LeadingAge requested first that CMS delay reporting on the proposed HOPE measures until at least 2028, and second, that after two years or eight quarters worth of data have been collected that CMS retest the validity and reliability of the measures with specific analyses on populations that experience health equity issues as well as exclusion populations. This is consistent with the publication of data related to the Hospice Item Set (HIS).
We strongly encouraged CMS to include a third HOPE Update Visits (HUV) time point at the first patient recertification and start of their second benefit period. As proposed, nearly a quarter of hospice patients will remain in hospice for 275 days, despite being on hospice for nearly a year, the HOPE tool would only collect one months’ worth of data on their care.
LeadingAge also recommended CMS move the implementation date for the updated CAHPS Hospice survey back to January 1, 2026, to allow survey vendors, EHR vendors, and hospices adequate time to develop and prepare for the web-mode of delivery, which is a key change to the survey.
