On Aug. 16, 2023, LeadingAge sent a letter to the Centers for Medicare and Medicaid Services (CMS) in partnership with three other national hospice-focused groups, to elevate concerns with specific issues on the Hospice Special Focus Program elements in the 2024 Home Health Prospective Payment System Proposed Rule. The letter is a pre-deadline comment on part of CMS-1780-P; LeadingAge will submit its full comments by the August 29 deadline.

LeadingAge is supportive of the idea of a special focus program for hospice, but is concerned that the algorithm proposed by CMS will not actually capture the poorest-performing hospices.

“The proposed Hospice Special Focus Program’s development is at a critical stage. We urge CMS to go back to the drawing board on several important issues, including data selection and scaling, and the weighting used in the SFP algorithm. Ensuring beneficiaries’ access to quality hospice care is an enduring priority of our nonprofit, mission-driven members; it is why we’ve long supported the creation of an SFP. The choices made now will determine whether it will achieve its intended result: improving poor providers’ performance and the sector overall,” said LeadingAge president and CEO Katie Smith Sloan. 

The letter outlines LeadingAge’s concerns regarding the algorithm and asks CMS to delay the program implementation in order to refine the algorithm and go through notice and comment rulemaking on a new version in future rulemaking. We also ask that providers be given a “preview year” where they can see where they would fall under the algorithm and both providers and CMS could see potential pitfalls with the methodology and smooth them out before going live.