As the Centers for Medicare and Medicaid Services (CMS) and the Center for Medicare and Medicaid Innovation (CMMI) explore the  hospice Value-Based Insurance Design Model (VBID), LeadingAge has taken advocacy action on two fronts.

In our February 14 response to CMMI’s Request for Information (RFI) for the VBID, LeadingAge strongly advised CMMI to exert extreme caution regarding closed networks for hospice providers and strongly opposed any change to current prior authorization restrictions for the VBID Hospice Benefit Component.

The response rejected the premise of two CMMI questions regarding “urgent care” and instead argued that all hospice services are medically necessary and immediately required. All hospice services should be protected regardless of whether a provider is in-network or out-of-network, and any access safeguards implemented in the VBID program should have the sole purpose of protecting beneficiaries from delays in care which could reduce the days spent in hospice.

We also strongly recommended CMS require plans to allow any willing hospice provider to participate if the provider meets the threshold for quality reporting or has been identified as having numbers too low to report. In the current comprehensive network development strategy, CMS states it will review VBID Hospice Benefit Component applications to assess an MAO’s process to ensure their hospice provider networks have adequate capacity and provide three examples of adequacy including staffing. LeadingAge commented that allowing MAOs to define staffing expectations for contracted hospices would be irresponsible and potentially lead to access issues in the long term.

In addition to LeadingAge’s individual letter, we joined with numerous other organizations (the American Academy of Hospice and Palliative Medicine, National Association for Home Care and Hospice, National Coalition for Hospice and Palliative Care, National Hospice and Palliative Care Organization, National Partnership for Healthcare and Hospice Innovation, and the Physician Associates in Hospice & Palliative Medicine) in sending a February 16 hospice community letter urging CMS not to allow Medicare Advantage (MA) organizations to limit beneficiary access to in-network providers without sufficient guardrails in place to minimize any disruptions in care and to not move forward with hospice prior authorization at this time.