On Tuesday, May 30, LeadingAge submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the FY2024 Hospice Wage Index Proposed rule. In addition to arguing for a higher overall increase in hospice payment to help providers as they navigate continued staffing challenges, our comments focused on the lengthy Request for Information (RFI) around utilization of the hospice benefit.

“Ensuring the availability of holistic, patient- and family-centered compassionate care is critical. Fair payment that covers the cost of care is a reasonable expectation. The proposed 2.8% payment rate increase is simply not sufficient to meet providers’ needs,” said LeadingAge president and CEO Katie Smith Sloan in a press statement elaborating on comments sent to CMS.  “In the FY2022 final rule, CMS reviewed cost pressures and raised the final rate to 3.8%. Since then, our mission-driven, nonprofit members’ costs have only risen. Consider, too, that demand for hospice services is growing because of our country’s rapidly aging population. We urge CMS to recognize the financial impact of both continued workforce shortages and inflation-driven operating expense increases on providers. Rates must be adjusted to ensure providers have a fighting chance to recruit and retain workers in a highly competitive employment market. Without staff, there is no care.”

Many of the responses to the RFI’s questions are echoed in memos and proposals LeadingAge has developed over the past six months and submitted to both CMS and members of Congress with the goal of modernizing and improving hospice benefit policies. In January of 2024, LeadingAge, in partnership with other national hospice associations, provided CMS and key Congressional stakeholders with 34 recommendations grouped into 11 core issue areas to improve hospice program integrity. The following month, LeadingAge responded to a request from a member of Congress, with a memo around reforms and improvements to the hospice benefit.

Finally, LeadingAge asked CMS to review existing data on hospice referrals from non-Medicare enrolled physicians and present those findings in future rulemaking before requiring physicians to enrollee in Medicare or properly opt-out.

To read the full comments click here.