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 Volume 22.07

Yesterday, March 30, 2022, CMS issued the proposed rule that would update Medicare hospice payment rates and the aggregate payment limitation (“CAP”) effective October 1, 2022.  2022-07030.pdf (federalregister.gov).

The proposed rate increase in Medicare payments is 2.7% effective October 1, 2022, and the CAP for the 2023 CAP Year, beginning October 1, 2022, is proposed at $32,142.65.

National rates, before geographical calculation of the wage component, are as follows:

Routine home care (days 1-60)                    $    209.14
Routine home care (days 61+)                     $    165.25
Continuous home care (daily maximum)    $ 1,505.61
Inpatient respite care                                     $    486.88
General inpatient care                                  $ 1,098.88

The proposed rule provides for a permanent solution for addressing significant declines in any specific hospice wage index.  The proposed rule provides a permanent cap on any negative wage index change to a five percent (5%) decrease from the prior year, regardless of the underlying reason for the change.

Hospices failing to meet quality measure reporting requirements continue to be subject to a two percent (2%) reduction in their daily payment.  It is noteworthy that the 2% will be increased to 4% beginning October 1, 2023.

This proposed 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 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.

The proposed rule requests comments on several issues of current importance to CMS, including:

  • What efforts does your hospice employ to recruit staff, volunteers, and board members from diverse populations to represent and serve underserved populations?  How does your hospice attempt to bridge any cultural gaps between your personnel and beneficiaries/clients?  How does your hospice measure whether this has an impact on health equity?
  • How does your hospice currently identify barriers to access in your community or service area? What are barriers to collecting data related to disparities, social determinants of health, and equity? What steps does your hospice take to address these barriers?
  • How does your hospice collect self-reported data such as race/ethnicity, veteran status, socioeconomic status, housing, food security, access to interpreter services, caregiving status, and marital status used to inform its health equity initiatives?
  • How is your hospice using qualitative data collection and analysis methods to measure the impact of its health equity initiatives?

Comments on the proposed rule must be received by CMS on or before May 31, 2022.

HOSPICE FINANCIAL MANAGEMENT ACADEMY

Mark your calendar for September 19-20, 2022.  The Health Group, LLC’s Hospice Financial Management Academy is scheduled to return to the Hotel Monteleone in New Orleans.  Additional details will be provided as available.