FY 2023 Hospice Proposed Rule

CMS staff provided an overview of the FY2023 Hospice Wage Index proposed rule. The proposed rule would provide a 2.7% increase to providers or $5.8 million for the hospice program. This is based on a 3.1% inpatient hospice market basket update and a .4% productivity adjustment. The hospice cap would be set at $32,142.65 based on the 2.7% increase. The rule also proposes a permanent cap of 5% on negative wage index changes. Comments on rules are due May 31, 2022. To read a full recap of the rule click here.

Home Health and Hospice Quality Reporting Update

May 2022 Hospice Care Compare Refresh

In March, Provider Preview Reports were made available for hospice providers on CASPER for the May 2022 Care Compare refresh. For this refresh, two new claims-based measures will be publicly reported: Hospice Care Index (HCI) and Hospice Visits in the Last Days of Life (HVLDL). The Hospice Item Set (HIS), hospice CAHPS survey, and the two new claims-based measures will exclude data from Quarter 1 and Quarter 2 of calendar year 2020. Providers have 30 days to review their quality measure results. The reports will be available for an additional 30 days after the initial review period for a total of 60 days. After the 60-day period the reports will be removed, CMS strongly encourages hospices to download and save their reports for future reference as they will not be available on CASPER after the 60 days.

Quality Updates in the FY2023 Hospice Wage Index

In addition to updates to payment, the FY2023 Hospice Wage Index proposed rule included updates on the future of hospice quality reporting and the Hospice Outcomes and Patient Evaluation, or HOPE tool. Included in these updates was information on the Hospice CAHPS Survey, public reporting information, a request for information on a health equity composite measure, and statutory updates to reporting requirements that will result in an increased 4% penalty for agencies which do not report on quality. To read a full recap of the rule click here. Staff also shared that a report from the Technical Expert Panel working on hospice quality measurement development was released on the CMS website.

Hospice Quality Reporting Program Quarterly Updates

On March 30, a quarterly informational email for hospice providers on the Hospice Quality Reporting Program (HQRP) was sent by Swingtech. The latest outreach communication can be found on the HQRP Requirements and Best Practices webpage in the downloads section. If providers would like to receive Swingtech’s quarterly emails (or update their email) they can email QRPHelp@swingtech.com. Providers should include their facility name and CMS Certification Number (CCN) along with any requested updates.

OASIS Updates

The Paperwork Reduction Act (PRA) public comment period for the implementation of the Outcome and Assessment Information Set (OASIS)-E closed on April 11. LeadingAge submitted comments on this PRA urging CMS to delay OASIS-E implementation for one more calendar year, those comments are available here. CMS shared they anticipate an updated draft of the OASIS-E to be available in early summer 2022. CMS also released quarterly OASIS Q&As. This document is updated on a quarterly basis and is intended to provide guidance on OASIS questions that were received by CMS help desks.

Home Health Services information on Care Compare

On March 25, CMS sent a provider announcement that they identified issues in iQIES affecting home health agency Services Provided values displayed on the HHA Provider Preview reports distributed on February 23. The process to collect and maintain the Services Provided information recently moved to iQIES and the support teams are working to address the issues associated with the move. CMS initially asked providers to review the Services Provided Information on the HHA Provider Preview Reports for the April 2022 refresh and contact their OASIS Education Coordinator (OEC) or OASIS Automation Coordinator if inaccuracies were identified. To allow more time to fix the identified issues, CMS decided for the April 2022 refresh, to publish the same Services Provided data for each home health agency that was posted on Care Compare for the January 2022 refresh. CMS is still encouraging provides to carefully review their Services Provided values, but there is not a deadline to this review. If agencies have questions, they can contact the iQIES Help Desk by phone at (800) 339-9313 or by email at iQIES@cms.hhs.gov. CMS continues to work to refine and rectify the update process moving forward. Steps for new and existing agencies to access reports is available here.

During the Q&A portion of the call, several providers noted inaccurate information from both state OASIS Coordinators and the iQIES help desk. Specifically, when agencies identified inaccuracies in the Service Provided information and called their state’s OASIS Coordinator or the iQIES help desk they were told if their agency had not had a survey on or after October 19, 2021, the Services Provided values could not be updated due to an issue with form 1572a. CMS staff responded that they were not sure why this answer was given and that OASIS Coordinators and iQIES staff should be able to update the Services Provided information. CMS staff will work on clarifying communications with OASIS Coordinators and iQIES staff.

Home Health CAHPS Survey Update

RTI, the contractor for the Home Health CAHPS survey, is still offering providers the opportunity to review the vendor training which was hosted in January. Interested agencies can reach out for a recording by emailing hhcahps@rti.org.

The exemption form is now available for CY2024 on the Home Health CAPHS website. As a reminder, exemption is available for agencies with 59 or fewer patients from April 2021 through March 2022.

The Home Health CAHPS Team posted a new issue of the HHCAHPS Coordination Team Quarterly Review (CTQR). The April 2022 issue includes agency participation tips for the brand new HHCAHPS Calendar Year 2024 Annual Payment Update period, and some insights from the Vendor Update Training session instant polls.

The HHCAHPS team reminded providers that the data submission deadline is April 21 and that home health agencies have a responsibility to review data submission reprots to make sure data was successfully submitted via the dashboard on the Home Health CAHPS website. The HHCAHPS team encouraged home health providers thinking of changing vendors to reach out to RTI at hhcahps@rti.org or 866-354-0985.

Home Health Value-Based Purchasing Model Update

CMS staff shared updates on the implementation of the Home Health Value Based Purchasing program, specifically pointing to the current website which has additional resources and will have more information in the coming weeks and months: https://innovation.cms.gov/innovation-models/expanded-home-health-value-based-purchasing-model

Benchmark and achievement thresholds for the demonstration will be posted on iQIES in mid-May. A model implementation guide will also be available in the coming months to help agencies prepared for January 1, 2023, when data collection will begin for payment adjustments in CY2025.

CMMI and CMS staff are planning to release updated materials on demonstration measures, podcast, and video on home health generally, as well as posting sample interim performance reports and annual total performance score and payment adjustment reports. To help providers understand these reports, CMS will host a webinar in August 2022. CMS encouraged providers to stay up to date on all changes by subscribing to the Expanded Home Health Value Based Purchasing ListServ through the link at the top of the model’s webpage. If providers have any questions, they can submit them to the help desk at hhvbp@lewin.com.

DME Update

The Center for Program Integrity joined the call to provide clarification on the prior authorization requirement changes to DME. In February, CMS released updated guidance in response to OIG reports and integrity efforts for improper payment. CMS is preparing guidance for instances when access to the DME listed in the update is urgently needed and the required two-day expedited review would delay care and risk the health or life of the beneficiary. Additional information on the DME updates is available here.

Additional Provider Questions

One provider asked about data collection on the hospice cap. Specifically, the provider was interested in running a beneficiary count and gross payments for a specific day. CMS did not have anyone on the call who could answer the question and asked the provider to send an email describing the issue.

Another provider asked for an update on the Home Health Review Choice Demonstration. CMS did not have anyone on the call who could answer that question and asked for the provider to send an email with their questions.

Finally, a provider shared a comment on the winddown of the Public Health Emergency. They saw an opportunity for regulatory waivers to be made available permanently including the ability for certain therapists to conduct the initial and comprehensive assessments. They urged CMS to make this flexiblity permanent. CMS appreciated the comment on the current flexibilities. The agency is considering all alternatives and current waivers, and which should continue or sunset. These conversations are being had now and staff are grateful for insight from the industry.