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HCA Comments on 2017 Hospice Proposed Rule

This week, HCA submitted extensive written comments on the 2017 proposed rule for Medicare hospice payment updates, wage index changes and quality reporting recently posted by the U.S. Centers for Medicare and Medicaid Services (CMS). You can download the comments here.

One concern addressed in our comments relates to CMS’s Medicare Choice Model (MCCM), where Medicare beneficiaries and dually eligible beneficiaries are able to receive hospice-like support services from certain hospice providers while concurrently receiving services provided by their curative care providers.

All three New York hospices participating in the current MCCM demonstration are HCA members; however, we have heard concerns about the exclusiveness for beneficiaries who cannot meet the 14 individual requirements before enrolling in the demonstration. Plus, CMS is only paying hospices $400 per-beneficiary per-month for palliative services. HCA urges CMS to loosen some of the requirements and increase the monthly capitation so providers can meet their costs while participating in this model.

On the payment side, our comments specifically address several items in the proposed rule, including revisions to the service intensity add-on (SIA) payment, so that other disciplines such as Licensed Practice Nurses (LPNs) can be included in the SIA, and the wage index, which is particularly problematic and in need of revision.

We provided item-by-item comments on quality reporting elements of the proposed rule, such as the Hospice Quality Reporting Program (HQRP) data submission process and future quality measures; the impact of Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey results on 2017 payments (an unfunded mandate in need of reimbursement support); and the issues associated with live discharge rates and double billing of Medicare Part D Medication Costs received by hospice beneficiaries.

 

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