FY2023 Hospice Wage Index Final Rule

The FY2023 Hospice Wage Index Final Rule was published on July 29. The rule finalized a change to Annual Payment Updates required by the Consolidated Appropriations Act 2021, which increased the payment reduction for hospices that fail to meet hospice quality measure reporting requirements from 2% to 4%. This change will take effect in FY2024 based on CY 2022 quality data.

While the final rule did not have any changes to the Hospice CAHPS survey, it did contain updates on a number of experiments to change the survey. The survey contractor tested a new mode experiment using a web-based survey administration option. The team also tested shortening the survey from the current 47 questions. CMS is reviewing results now and any changes to the survey will be included in future rulemaking. The final rule also provided an update on the Hospice CAHPS Five Star Rating which went into effect in the August 2022 Hospice Care Compare refresh. Providers saw the first Provider Preview Reports for the new Hospice CAHPS Five Star Rating November 2021 and March 2022.

CMS included an update on progress on the Hospice Outcomes and Patient Evaluation (HOPE) patient assessment tool. Beta testing is currently underway with three different disciplinary assessments being tested; nursing, social work, and chaplain services. This beta test will support refinement of the final draft items and assesment time points. Once testing and analysis are complete the tool will be included in future rulemaking for feedback along with proposed implementation timelines.

During the review of the final rule CMS also touched on the RFI on Health Equity and the development of a structural health equity measure. CMS announced a technical expert panel (TEP) earlier this year that, with the support of Abt Associates, will review, discuss, and develop a structural measure for both home health and hospice settings.

Finally, included in the final rule was an update on the hospice survey and enforcement implementation from Section 407 of the Consolidated Appropriations Act of 2021. During the call, CMS reviewed the key components of these changes including requirements for reporting survey data on Hospice Care Compare, requiring state surveyors and accrediting organizations to use the same forms for deficiency reports, development of comprehensive training and testing for surveyors on the writing of plans of care, and the development of a hospice hotline for survey support. CMS staff noted that another TEP was announced to help develop a Special Focus Program (SFP) for poor-performing hospices. CMS shared that the TEP will complete its work in 2023 with future rulemaking expected in FY2024.

HQRP Updates

CMS shared an update on one of the newest measures in the hospice quality reproting program, the Hospice Visits in the Last Days of Life (HVLDL). The National Quality Forum (NQF) endorsed the claims-based measure as NQF #3645. HVLDL reflects the proportion of hospice patients who received in-person visits from a registered nurse or a medical social worker on at least 2 of the final 3 days of life. HVLDL is the re-specified measure replacing the Hospice Item Set (HIS)-based measure Hospice Visits When Death is Imminent (HVWDII). Public reporting for HVLDL will began in August 2022 and will replace public reporting of HVWDII.

Public Reporting

CMS reviewed the August 2022 Care Compare refresh which include the inaugural publication of two new claims based HVLDL and the Hospice Care Index as well as the first publication of the Hospice CAHPS Five Star Rating. The next refresh for Hospice Care Compare will be in November 2022 and it will update only the claims-based measures and the HIS. Providers received their newest Provider Preview Reports on August 19^th. CMS stressed the importance of downloading these reports within 60 days of receiving them as they will not be maintained in the CASPER system. The new Provider Preview Reports will also include a new variable, “Claim Count,” which shows how many claims were used to calculate claims-based measures for individual hospices.

Resources

CMS shared several new resources for hospices on the quality reporting program:

• Getting Started with Hospice CASPER Quality Measure Reports: This fact sheet contains information about the two Certification and Survey Provider Enhanced Reporting (CASPER) Quality Measure (QM) reports available to hospice providers. Additionally, this fact sheet includes one potential model hospices could employ to use the QM reports for quality improvement.
• Getting Started with Hospice CASPER Review and Correct Reports: This fact sheet is intended to help providers understand what CASPER reports are and how to interpret and use the Hospice Item Set (HIS) data contained within them. These reports are confidential and contain details about the HIS-based quality measure (QM), Comprehensive Assessment at Admission (NQF #3235). Review and Correct Reports provide information at the hospice-level, and about individual patients, if desired.
• Third Edition HQRP Public Reporting Tip Sheet: The Third Edition HQRP Public Reporting Tip Sheet is meant to support providers understand public reporting for the Hospice Quality Reporting Program in the midst of the COVID-19 Public Health Emergency (PHE). This tip sheet provides updates to the Second Edition HQRP Public Reporting Tip Sheet. The Third Edition HQRP Public Reporting Tip Sheet is available under Provider Toolkit on the HQRP Requirements and Best Practices page.

Q&A

During the Q&A portion of the call, providers received some information on timelines for a number of changes occuring in the hospice quality reporting program:

1. CMS anticipates completing HOPE Beta testing in Spring 2023. Following the completion and analysis, CMS and their contractor Abt Associates will release additional data on the beta testing. The tool will be proposed for implementation in future rulemaking. While CMS did not know exactly when HOPE would be implemented, staff committed to providing enough time for implementation and staff training.
2. CMS anticipates the Health Equity TEP to develop a structural measure for home health and hospice to will complete their report in 2023.
3. The CMS anticipates work from the SFP TEP for poor performing hospices will be completed in 2023 with future rulemaking on an SFP program in FY2024.
4. CMS provided clarification on the timeline to update the new Hospice CAHPS Five Star Rating. These ratings will be updated every other quarter, or every six months, with the previous eight quarters worth of data. The next update will take place in the February 2023 and cut points will be recalculated with this update to ensure stable estimation. Currently, CMS is not looking at lowering the survey response threshold, which is 75 respondents. Additionally, while CMS discussed several experiments, they did with the Hospice CAHPS tool, shortening the survey and looking at online completion, but they do not have a timeline to make those changes.