HCA has submitted our comments on the 2016 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). Our comments can be read here.
On the payment side, our comments specifically address several items in the proposed rule, including: revisions to the routine home care rate, the service intensity add-on payment, the inpatient aggregate cap accounting year timeframe, and the wage index which is particularly problematic and in need of revision.
We also provide 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 reporting of diagnoses on hospice claims.