Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
On Wednesday, March 30, 2022, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule (CMS-1754-P) that would provide routine updates on the development of a patient assessment instrument Hospice Outcomes and Patient Evaluation (HOPE) assessment tool, which would contribute to the patients plan of care when adopted within the Hospice Quality Reporting Program (HQRP). CMS also proposes an update on potential future quality measures within the HQRP based on HOPE and administrative data including HOPE-based process measures as well as hybrid quality measures which could be based upon multiple sources including HOPE, claims and other data sources. This rule also proposes an update on the CAHPS Hospice Survey and seeks information on our Health Equity Initiative within the HQRP.
The proposed rule went on display on March 30, 2022, at the Federal Register’s Public Inspection Desk and will be available under “Special Filings,” at https://www.federalregister.gov/public-inspection. The scheduled publication date in the Federal Register is April 4, 2022.
The 72-page unpublished PDF version is found here.
For further information, visit the Hospice Center | CMS webpage.
Proposed Medicare Hospice Payment Policies:
This proposed rule proposes a permanent, budget neutral approach to smooth year-to-year changes in the hospice wage index. Specifically, we are proposing a permanent cap on negative wage index changes greater than a 5% decrease from the prior year (regardless of the underlying reason for the decrease) for hospices in the FY 2023 proposed rule.
Routine Annual Rate Setting Changes:
As proposed, hospices would see a 2.7% ($580 million) increase in their payments for FY 2023. The proposed 2.7% hospice payment update for FY 2023 is based on the estimated 3.1% inpatient hospital market basket update reduced by the productivity adjustment (0.4 percentage point). Hospices that fail to meet quality reporting requirements receive a 2-percentage point reduction to the annual market basket update for FY 2023.
The hospice payment update includes a statutory aggregate cap that limits the overall payments per patient that is made to a hospice annually. The proposed cap amount for FY 2023 is $32,142.65 (FY 2022 cap amount of $31,297.61 increased by 2.7%.
Hospice Quality Reporting Program:
This rule provides an update on the development of a patient assessment instrument, titled HOPE, which would contribute to a patient’s plan of care when adopted. This includes an update on the BETA testing and derivatives that will be achieved during this phase of testing, such as burden estimates and timepoints for collection, as well as additional outreach efforts that will be conducted during and after BETA testing and during our future plans for adoption. CMS also discusses potential future quality measures within the HQRP based on HOPE and administrative data, including HOPE-based process measures and hybrid quality measures, which could be based upon multiple sources that include HOPE, claims, and other data sources.
This rule announces a potential future update to the CAHPS Hospice Survey, which is used to collect data on experiences of hospice care from primary caregivers of hospice patients. In particular, CMS is providing an update on a mode experiment whose goal was to test the effect of adding a web-based mode to the CAHPS Hospice Survey.
In this proposed rule, we are seeking information on our Health Equity Initiative within the HQRP by describing our current assessment of health equity within hospice. We are also seeking input on a potential future structural measure as well as responses to specific questions that would further inform future efforts.