Health Law Daily $180M payment increase, clinical doc reporting for hospices in FY 2018
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Wednesday, August 2, 2017

$180M payment increase, clinical doc reporting for hospices in FY 2018

By Anthony H. Nguyen, J.D.

Effective October 1, 2017, Hospices serving Medicare beneficiaries will receive a $180 million or 1 percent increase in their payments for fiscal year (FY) 2018 under a Final rule updating the hospice wage index, payment rates, and cap amounts. In an advance releaseof the Final rule, set to publish on August 4, 2017, CMS also adopted two global Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Hospice Survey measures and six composite CAHPS Hospice Survey-based measures. The CAHPS Survey is a component of the Hospice Quality Reporting Program (HQRP) and is important for the hospice community because the results of the survey will allow for comparisons on a national basis (see Hospices see modest payment increase, new clinical doc reporting for FY 2018, May 3, 2017). In the Final rule, CMS noted that the data would help beneficiaries to select a hospice program, as well as encourage hospices to improve quality of care. The Final rule also outlines how these measures will be calculated based on the survey data.

Additionally, as required by section 1814(i) of the Social Security Act, the rule finalizes updates to the hospice payment rates for FY 2018. The Final rule specifies public reporting measures derived from the CAHPS Hospice Survey and also provides an update on the Hospice Quality Reporting Program (HQRP) consistent with changes to the Social Security Act as added by section 3004(c) of the Affordable Care Act (ACA) (P.L. 111-148). Hospices that fail to meet these quality reporting requirements will receive a 2.0 annual percentage point reduction to their payments.

CMS will begin public reporting HQRP data via a Hospice Compare Site in August 2017 to help customers make informed choices. While the HQRP includes both the Hospice Item Set (HIS) and Hospice CAHPS Survey data, this new website will initially display only HIS data. The public display of the Hospice CAHPS Survey data will be added in winter 2018. In the Final rule, CMS has also established policies and procedures associated with the public reporting of the quality measures used in the Hospice Program, including release of the aggregate quality data file and the Provider Preview Reports.

FY 2018 rates. The cap amount for FY 2018 will be $28,689.04, which is the 2017 cap amount of $28,404.99 increased by 1 percent. The hospice payment system includes a statutory aggregate cap that limits the overall payments made to a hospice annually. As mandated by the Improving Medicare Post-Acute Care Transformation Act of 2014 (P.L. 113-185) (IMPACT Act), the cap amount for accounting years that end after September 30, 2016, and before October 1, 2025, must be updated by the hospice payment update percentage, rather than the Consumer Price Index (CPI).

In addition, section 411(d) of the Medicare Access and CHIP Reauthorization Act of 2015 (P.L. 114-10) (MACRA) amended the Social Security Act to set the market basket percentage increase at 1 percent for hospices in FY 2018. Thus, hospices will generally see an aggregate $180 million or 1.0 percent increase in their payments for FY 2018.

HQRP extensions and exemptions. For FY 2019 payment determination and subsequent years, CMS will extend from 30 calendar days to 90 calendar days after the date of an extraordinary circumstance has occurred that a hospice has to submit a request for an extension or exception for quality reporting purposes. The change aligns the HQRP with the other post-acute care quality reporting programs, as well as the Hospital Inpatient Quality Reporting Program, and will give additional time for providers to focus on operations related to patient care should a situation arise, such as an unforeseen environmental emergency.

Claims-based measures. CMS did not add new measures based on the Hospice Item Set, but noted that it would continue to consider two measure concepts for future years: (1) potentially avoidable hospice care transitions and (2) access to levels of hospice care. Both measure concepts would be claims-based measures.

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