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Volume 24.11

While the drafted Hospice Care Accountability, Reform, and Enforcement Act (“Hospice Care Act”) is generally regarded as a continuation of efforts to target bad actors operating in the hospice space, it would not only significantly impact negligent and fraudulent operators, but it would also provide significant challenges to quality providers.  All hospice providers whether small or large, proprietary or tax-exempt, freestanding or provider-based, need to gain an understanding of the drafted provisions.

Even though no legislative action is expected during the remainder of 2024, the draft legislation clearly provides a blueprint of those payment, service delivery, and additional integrity provisions deemed important to legislators.  Informed sources see increasing support for the draft legislation, although hopefully with modification.

Hospices can expect:

  • Benefit modifications especially related to respite care provisions.
  • Reimbursement changes and increased complexity based on service utilization.
  • Rebasing of payment rates based on cost report data and claims submissions.
  • Cost reporting modifications.
  • Enhanced integrity measures targeting ownership, key employees, and physicians.
  • CAP reforms.
  • Quality data submission implications, including the finalized HOPE tool and more.

The entire draft legislation is available here. The upcoming “2024 Hospice Financial Administration Conference” will focus on payment and integrity reforms including practical guidance in preparing for the reforms under consideration as well as those already finalized for implementation.

HOSPICE FINAL RULE RELEASED

CMS has released the FY2025 Payment Rule which updates the hospice wage index, payment rates, and aggregate CAP amount for the year ending September 30, 2025.  The rule clarifies policy related to the election statement and the notice of election.  Additionally, the rule finalizes changes to the Quality Reporting Program.

Final rates, subject to wage index modification, are as follows:

Routine home care (days 1-60)              $    224.62
Routine home care (days 61+)               $    176.92
Continuous home care (hourly)             $      67.44
Inpatient respite care                              $    518.78
General inpatient care                            $ 1,170.04

The hospice CAP will increase to $34,465.34 for the 2025 CAP Year.  The CAP is not adjusted based on geography.

Additional details will be provided in upcoming releases.  The full text is available at 2024-16910.pdf (federalregister.gov).

TENTATIVE AGENDA SET FOR 2024 HOSPICE FINANCIAL ADMINISTRATION CONFERENCE

The tentative agenda has been set for the 2024 Hospice Financial Administration Conference.  The program, scheduled for September 30 – October 1, 2024, will be held at the Hilton Phoenix Tapatio Cliffs Resort in Phoenix, Arizona.  Early registration has been extended through August 10, 2024, due to the delay in setting the tentative agenda.

Special rates have been secured with the Hilton Phoenix Tapatio Cliffs Resort; however, to secure these rates, call (602) 866-7500 and inform the hotel that you are attending “The Health Group, LLC Hospice Financial Administration Conference” or, more conveniently, secure your room online at https://book.passkey.com/event/50849453/owner/3244/landing Many benefits have been secured for conference attendees.

Speakers include professionals of The Health Group, LLC, Melinda Gaboury, co-founder and CEO of Healthcare Provider Solutions, Inc., and Bryan S. Bailey, Shareholder with Milligan Lawless (Phoenix office) who practices in healthcare fraud and abuse. Registration and other information are available at https://healthgroup.com/education/.