FY 2023 Hospice Final Rule

On July 29, the FY2023 Hospice Wage Index final rule was published on the Federal Register. The final rule includes an updated payment rate, aggregate hospice cap, and wage index. These adjustments represent an additional $824 million increase based on a 3.8% market basket update instead of the origionally proposed 2.7% market basket update. CMS also finalized a permanent 5% budget neutral cap on wage index decreases for FY 2023 and subsequent years.

The final rule also includes updates to the Hospice Quality Reporting Program (HQRP). The HRQP annual payment update will be reduced by 2% for all hospices which fail to report on quality. This APU will increase to 4% starting in FY 2024 based on CY 2022 quality data submission. The rule also updated information on public reporting for HQRP. In August 2022, several additional quality measures will be publicly reported on hospice compare including the Hospice Care Index (HCI), Hospice Visits in the Last Days of Life (HVLDL) and the Hospice CAHPS Five Star Rating. CMS also shared updates on recent mode experiments for the Hospice CAHPS survey including, shortening survey to increase response rate and adding supplemental survey items on race and ethnicity. CMS thanked commentors for their feedback on the development of a health equity structural measure for hospice and noted that a Technical Expert Panel (TEP) will be used to inform future work on a measure.

CMS also shared that Abt Associates is still recruiting hospices for the HOPE patient assessment beta testing process. They are seeking input from hospice teams and looking at use of the tool in field which will help refine the final draft. CMS will be proposing the use of the assessment in future rulemaking once testing is complete.

For a full recap of the FY 2023 Hospice Wage Index Final Rule, read this article.

Hospice CAHPS

Staff shared that the Hospice CAHPS Five Star Rating would be released in the upcoming August 2022 Hospice Compare refresh. Information about the star rating as well as FAQs are available on the Hospice CAHPS website.

Staff also clarified that providers must use an authorized and approved CAHPS hospice vendor for surveys. To authorize a change in hospice survey vendors, providers must complete a new hospice vendor authorization form 90 days prior to first time the new vendor will submit data to the hospice CAHPS warehouse.

The CAHPS team will be holding their annual updated trianing which is mandatory for survey vendors and voluntary for hospice providers. CMS will offer an Introduction to the CAHPS Hospice Survey self-training module starting the week of September 19, 2022 and a CAHPS Hospice Survey Update Training on September 29, 2022 from 11:00am-1:15pm EDT. These trainings are intended for hospices and survey vendors that participate in the CAHPS Hospice Survey, as well as other interested individuals and organizations. Please see the list of required organizations for each training session below. Registration will close August 25, 2022 at 5:00p.m. EDT.

Introduction to CAHPS Hospice Survey Training

When: Monday, September 19 through Thursday, September 22, 2022 (via a self-training module)

Who is Required to Participate:

• Required: New Project Managers for currently approved vendors
• Optional: Recommended as a training/refresher course for new staff members at hospices or organizations that are currently approved to administer the CAHPS Hospice Survey

Steps to Meet Requirement:

Organizations must:

• Register for Introduction to CAHPS Hospice Survey Training
• Review the training slides, submit an Attestation Form upon completion, and complete and submit an online quiz. Please see the “Training Registration Form” page for deadlines.

CAHPS Hospice Survey Update Training

When: September 29, 2022, 11:00 am – 1:15 pm EDT (via Webinar)

Who is Required to Participate:

• Required: All survey vendors currently approved to administer the CAHPS Hospice Survey
• Required: Subcontractors or other organizations who are responsible for major functions of CAHPS Hospice Survey administration (e.g., mail/telephone). Survey vendors must ensure that their subcontractors participate in the appropriate CAHPS Hospice Survey Training.
• Optional: Hospices, as well as other interested individuals and organizations

Accessing the Self-training Module: A link to the “Introduction to CAHPS Hospice Survey Training” page will be sent to registered organizations the week prior to training. The training page will provide access to the slides, agenda, and the Attestation Form. Please visit the Training Registration Form to register for the 2022 CAHPS Hospice Survey Training sessions.

Home Health CAHPS Survey

Staff shared a reminder that the public reporitng preview for the October 2022 Home Health Compare refresh are available on the HHCAPHS website in the home health agency portal. The next data submission deadline is October 20, 2022. Home health agencies were encouraged to start checking vendor submission on or around October 1, 2022.

The October 2022 Home Health CAPHS Quarterly Newsletter will be released on October 3, 2022. These are a good source of information and a fun way to find out more about the survey process.

Finally, the CY 2024 participation exemption request form is up on HHCAPHS website. Agencies who meet the criteria for exemption have until March 31, 2023 to submit the form. Exemption is available to agencies with 59 or fewer HHCAHPS-survey eligible patients between April 1, 2021 and March 31, 2022.

Home Health Value Based Purchasing (HHVBP)

Staff shared that comment on the CY 2023 Home Health Proposed Rule are due August 16, 2022. This year’s proposed rule includes a request for comment on expanded HHVBP model proposal for potential future application of health equity considerations.

CMS is treating CY 2022 as a pre-implementation year for the expanded HHVBP model which will end on December 31, 2022. The first performance year will start January 1, 2023, and CY 2025 will be the first payment year. Many resources in addition to model guide and FAQ have been posted to the HHVBP website including quality measures information, total performance score calculations, and quality improvement podcasts. One new resource the HHVBP technical assistance team highlighted was instructions on how to access agency level quality measures data for the Interim Performace Report (IRP) and Annual Performance Reprot (ARP). These sample IPR and APR were issued on iQIES on July 29th to provide home health agencies examples of content and format of the reports.

CMS will host a webinar on August 25 at 2 PM ET titled Navigating Interim Performance Reports (IPRs) and the Annual Total Performance Score and Payment Adjustment Report (Annual Report). This event will assist HHAs with understanding the format and content of the reports specific to the expanded HHVBP Model. Home health agencies are encouraged to download and review the reports prior to attending the webinar. Registration available at the following link: https://us06web.zoom.us/webinar/register/WN_SpSWv54gTCedb3azUWI4eA

Hospice Survey and Certification Enforcement

CMS is launching a Technical Expert Panel (TEP) to help develop a hospice Special Focus Program for underperforming hospices. The solicitation for nominations to the TEP closed August 12, 2022.

Additional Audience Questions

One caller asked when an updated draft of OASIS-E forms would be availabe. The individual noted that the most recent published OASIS-E forms, from May 2022, are not consistent with data submission specification document which was released in July. One specific example of differences between the two documents is the question on race and ethnicity. In the data submission document, there is an additional option to “declined to answer” which is not on the May version of the OASIS-E form.

CMS staff clarified that what is on the OASIS webpage is most current information they had to share. The final OASIS-E instrument will not be availabe until it has gone through the Office of Management and Budget (OMB) approval process.

The caller stressed the importance of making the form submitted for OMB approval available to electronic health record vendors as soon as possible so they can update their software accordingly for the January 1, 2023, OASIS-E implemenation deadline.