November 1, 2023 Washington, DC — The four preeminent national hospice organizations – LeadingAge, the National Association for Home Care & Hospice (NAHC), the National Hospice and Palliative Care Organization (NHPCO) and the National Partnership for Healthcare and Hospice Innovation (NPHI) – strongly oppose the final design of the hospice special focus program (SFP) as presented in the CY2024 Home Health Prospective Payment System Rate Update (CMS-1780-F), released by the Centers for Medicare and Medicaid Services (CMS) today.
CMS’ decision to progress using a flawed methodology for the SFP algorithm will threaten the ability of millions of older adults and other hospice beneficiaries to access quality hospice care.
In addition, the implementation of the poorly designed algorithm, which has been widely criticized by congressional leaders, technical expert panel participants, and hospice community and association leaders, will hinder a widely shared goal of improving sector quality. As a community, we are profoundly disappointed with this decision.
Over the past two years, the national hospice associations have presented CMS — in letters, in-person meetings and via other channels — with a wide array of research and well-supported advocacy outlining our concerns. We’ve reiterated those concerns to the White House Office of Management and Budget and Domestic Policy Council as well. Nonetheless, CMS has opted to ignore our feedback, along with concerns from congressional leaders dating as far back as 2021.
To be clear: our associations support the spirit and intent of the SFP, which, in keeping with the HOSPICE Act passed in 2020, aims to improve poor performing hospices. CMS’ approach is not aligned with congressional intent, nor does it effectively identify the lowest quality performing providers, and does not achieve the goals set forth in the HOSPICE Act.
On behalf of hospice provider members serving beneficiaries around the country, our organizations are committed to continued advocacy on this issue. We will explore all options to prevent the flawed SFP design from moving forward and will work to find a solution which accomplishes the goals of the hospice community and Congress for improving the quality of care delivered.
