Hospice Outcomes & Patient Evaluation (HOPE) Beta Testing

The LeadingAge Hospice Member Network met with Abt Associates regarding the Hospice Outcomes & Patient Evaluation or HOPE patient assessment instrument. Abt is currently recruiting Medicare certified hospices to support beta testing of the tool. Recruitment is ongoing and training will occur on a rolling basis. Data collection begins when training is completed and is expected to continue through fall 2022. While any Medicare-certified hospice can participate, the tested does require certain staffing expectations which hospice members will need to consider before committing to testing.

• Testing requires 1-2 joint visits per week between different disciplines
• CMS anticipates hospices will need 6-8 registered nurses, 3-4 social workers, and 3-4 chaplains
• For joint visits, two registered nurses visit one patient at the same time to complete the HOPE nurse assessment
• Two social workers visit the patient at the same time to complete the HOPE social work assessment
• Two chaplains visit the patient at the same time to complete the HOPE chaplain assessment
• One of the two registered nurses, social workers and chaplains may attend their joint visit via video call, such as Zoom
• HOPE assessments are completed at hospice admission, for symptom reassessment and at live discharge

During the conversation with members Abt shared a few critical clarifications on testing requirements:

• Testing does require two clinicians to be present during the assessment, HOWEVER, one clinician can be present through audio and visual telehealth. This may make it more feasible for a hospice agency to particpate in the testing.
• The data is being gathered electronically through a research data collection platform so there is no additional investment in EHR updates or paper-based assessments for participating agencies.
• There was a concern that only larger agencies would be able to participate due to staffing shortages, skewing testing results. The Abt team clarified that this beta test is looking at the interrelated reliablity of the questions themselves and that previous tests were conducted with a more diversified sampling of hospices to understand the impact and implication of the assessment on a more representative sample of hospices including regional variations, small and large hospices, and other factors.

After beta testing is completed a draft of the tool will be released. The team at Abt Associates is happy to speak with any providers who feel they could meet the requirements for beta testing. Hospices can review the requirements here and email the Abt team at HOPETesting@abtassoc.com.

FY2023 Hospice Wage Index Final Rule

The network reviewed the FY2023 Hospice Wage Index Final Rule during the meeting. After reviewing inflationary data from their contractors, CMS updated the hospice market basket update for FY2023 to 3.8% from the previously proposed 2.7%. While it still does not meet the peak national inflation rate of 8%, it was a welcome change to the final rule. In addition to the rate increase, CMS finalized their plan to cap negative wage index adjustments to 5% in FY2023 and future years.

In the quality section of the final rule, an update was given on the HOPE beta testing, as well as the update of publicly reported hospice quality measures. In August, two new claims-based measures will be reported on Hospice Compare; Hospice Care Index and Hospice Visits in the Last Days of Life. Additionally, the Hospice CAHPS five-star rating will be released in August. The final rule also provided an update on the feedback provided by hospices on health equity. CMS announced in June that they would be developing a Technical Expert Panel (TEP) to review the proposed health equity structural measure for home health and hospice providers.

Finally, the final rule included information on the hospice survey and enforcement procedures. CMS announced another TEP that will look at the development of a Special Focus Program (SFP). This program would be for poor-performing hospices programs to include a range of remedies to address and improve quality issues as well as procedures for appealing survey determinations.

A full review of the final rule is available here.

Policy Update

Telehealth Legislation Advances in the House: The House passed H.R. 4040, legislation which would extend current telehealth flexibilities beyond the Public Health Emergency (PHE). This bill would extend various flexiblities beyond PHE including the hospice face-to-face flexiblities which were extended through legislation earlier this year to 150 days past the end of PHE. To be clear, the PHE is not over so these previous legislative provisions have not kicked in. If this new legislation were to pass, it would extend flexiblities until December 31, 2024. The legislation also allows the home to be an originating site for telehealth. It is likely that the PHE will be extended again before the Senate takes it up this legislation. If the Senate does move forward with this work, the timing will probably be at end of the year in December as part of a larger year end package, but it could also be a included in legislation funding the government for a few more months in September.

Inflation Reduction Act: A package of major administration priorities moved forward in the Senate after much debate. The legislation includes provisions on climate change as well as Medicare prescription drug negotiations and out of pocket caps on Medicare Part D. The Medicare drug spending has been in the works on for years starting in House. The legislation will also extend American Rescue Plan Act health insurance subsidies for three years. While LeadingAge is disappointed to not see HCBS and housing workforce in the final legislations we will keep pushing on those priorities.

Appropriations Moves Forward: In the appropriations process, the House marked up and passed 6 of 12 spending bills. In the Senate, the draft bills have been released but they have not gone through committee hearings yet. LeadingAge worked hard to get language in the House appropriations reports around bereavment care, requiring the Agency for Healthcare Research and Quality (AHRQ) work with stakeholders on consensus standards on bereavement care. Additionally, a second piece of report language would scope the need for bereavment services, specifically, community bereavment and what access problems looks like.

203849639. and Continued Workforce Outreach: The Senate is out on recess until September 6 while the House will return to DC next week to pass the Inflation Reduction Act. LeadingAge members are encouraged to reach out to their members of Congress during recess to discuss LeadingAge’s Aging Services Workforce Now campaign. LeadingAge is working with state associations to help set up meetings with members of Congress to discuss the workforce crisis. More information on that campaign can be found here.

CMS Home Health, Hospice, and DME Open Door Forum Announced: The Open Door Forum will be hosted on Wednesday, August 10 from 2 to 3pm ET. [This LeadingAge article covers the top announcements from the ODF].

Hospice Care Index Measure (HCI) Informational Video: CMS released a video describing the Hospice Care Index (HCI) measure. This video provides an overview of the new HCI claims-based measure, which combines several quality indicators into a single index score that patients and families can readily use to compare their hospice options. With the inclusion of this measure, the Medicare Hospice Quality Reporting Program offers patients, families, and caregivers a more comprehensive and holistic view when making decisions about hospice care.

Hospice Quality Reporting Program (HQRP) Explanatory Video: CMS released a new video resource providing an overview of the HQRP. The video introduces the purpose of the HQRP, how data is collected for use in HQRP, and the quality measures included in HQRP.

OIG’s Nationwide Review of Hospice Eligibility: The Office of Inspector General’s (OIG) recently launched nationwide review of hospice beneficiary eligibility. In January 2022, OIG announced in their workplan a national review of hospice beneficiary eligibility. This review is based on several compliance audits performed by the Office of Audit Services for individual hospice providers. Each of those audit reports identified findings related to beneficiary eligibility. OIG will perform a nationwide review of hospice eligibility, focusing on those hospice beneficiaries that have not had an inpatient hospital stay or an emergency room visit in certain periods prior to their start of hospice care. The OIG has begun sending out requests for records to hospices across the country. The review will look at 100 patient records from 100 different hospices. The turnaround time is only 21 days for this OIG request. Most requests are looking at the first certification period in the spring of 2021.

CMS Issues QRP Non-compliance Notices Impacting FY2023 Payments: Hospice providers should check their CASPER folders in QIES to see if they have received a non-compliance notice from CMS related to their CY2021 reporting for their respective Quality Reporting Programs. Providers who are non-compliant will have their Medicare FFS rates reduced 2% beginning October 1, 2022. For providers who contract with Medicare Advantage and Special Needs Plans, this may also impact those rates if their contract pays them based upon a percentage of Medicare FFS. These notices were placed into those folders on Wednesday, July 13 and include information on why the provider failed compliance. This information can be used to improve reporting processes within your organization. Hospice reconsideration information is here. As a reminder starting with FY 2024, the Hospice QRP penalty increases to a 4% reduction in their Annual Payment Update based upon CY 2022 data and reporting.