What Do You Think? CMS wants your opinion. CMS wants your opinion YOUR CHANCE TO BE HEARD 5/16/17

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1 What Do You Think? CMS FY 2018 Hospice Proposed Rule What is a proposed rule? YOUR CHANCE TO BE HEARD May 2017 Beth Noyce, RN, Home Health & Hospice Consultant beth@noyceconsulting.com BSMJC, HCS-D, HCS-H, COS-C AHCC Advising Board Member 2 CMS wants your opinion FY 2018 Hospice Proposed Rule seeks feedback/comments on proposed: Updates to the hospice wage index, payment rates, and cap amount for fiscal year (FY) New quality measures for the hospice quality reporsng program. Enhanced data collecson instrument. Plans to publicly display quality measures and other hospice data. CMS wants your opinion FY 2018 Hospice Proposed Rule comments due June 26, Time to tell CMS what hospices need. Comments somesmes sway CMS plans for final rule. If only CMS would... 1

2 CMS wants your opinion Comments must be received by 5 p.m. on June 26, 2017, the close of the comment period: Electronically: hxp:// Follow the "Submit a comment" instrucsons. Regular postal mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, AXenSon: CMS-1675-P, P.O. Box 8010, BalSmore, MD Express or overnight mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, AXenSon: CMS-1675-P, Mail Stop C , 7500 Security Boulevard BalSmore, MD By hand or courier. How to achieve CMS transparency, flexibility, simplificason & innovason JOIN THE CONVERSATION 6 In addison to Proposed Rule comments, CMS wants ideas to bexer achieve transparency, flexibility, program simplificason and innovason to inform future hospice regulatory acson. How can Medicare Improve the health care delivery system? Decrease health care s bureaucracy and complexity? Reduce burden for clinicians, providers and pasents? 2

3 CMS wants to: Increase care quality and decrease costs. Making the health care system more effecsve, simple, and accessible while maintaining program integrity and prevensng fraud. CMS wants regulatory, sub-regulatory, policy, pracsce and procedural ideas to bexer accomplish these goals, such as re-designing, eliminasng, or streamlining: Payment system ReporSng. Monitoring and documentason requirements; Medicare also solicits ideas on designing: OperaSonal flexibility. Feedback mechanisms and data sharing that would enhance pasent care, support the doctor-pasent relasonship in care delivery, and facilitate pasent- centered care within hospices. Ideas could also include recommendasons regarding when and how CMS issues regulasons and policies and how CMS can simplify rules and policies for beneficiaries, clinicians, providers and suppliers. 3

4 Proposals should be clear and concise and include data and specific examples. Analysis regarding CMS authority is welcome if a proposal involvea novel legal quessons. CMS will acsvely consider all input in developing future regulatory proposals or future sub-regulatory guidance. RouSne Annual Rate Sehng Changes $180 MILLION MORE FOR HOSPICE 14 1 % Raise for Hospice Hospice market basket percentage increase for FY 2018 is 1%. About $180 million increase calculated as 2017 cap amount ($28,404.99) X.01. The aggregate cap limits the overall payments made to a hospice annually, updated by the hospice payment update percentage. Cap amount for FY 2018 will be $28, Face-to-Face Encounters at Admission/Referral source to verify CTI? CTI DOCUMENTATION CHANGES 16 4

5 Proposed: Specify that the referring physician s and/or the acute/post-acute care facility s medical record would serve as the basis for inisal hospice eligibility determinasons. Clinical informason from the referring physician and/or acute/post-acute care facility supporsng a terminal prognosis would be obtained by the hospice prior to elecson of the benefit, when determining cersficason and subsequent eligibility. CMS: 2006 Hospice Wage Index final rule (70 FR 70538), we received comments stasng that it is common pracsce for hospices to obtain clinical informason from the referring physician, which is then documented in the pasent s hospice medical record. CMS: Longstanding expectason that the referring physician/acute/post-acute care facility s clinical documentason serves as the basis of the cersficason of terminal illness. This potensal clarifying regulatory text change would be in alignment with benefit eligibility criteria that the individual must be cerufied as terminally ill prior to receiving hospice services, and fundamentally could not be determined by hospice documentauon obtained ayer admission. 5

6 Proposed: DocumentaSon of an in-person visit from the hospice Medical Director or the hospice physician member of IDG could be used as documentason to support inisal hospice eligibility determinasons, only if needed to augment the clinical informauon from the referring physician/ facility s medical records. Comments on current processes used by hospices to ensure comprehensive clinical review to support cersficason and any alternate suggesuons for supporsng clinical documentason sources are also encouraged. CAHPS 8 New CAHPS measures REVIEWING FAMILY SATISFACTION Proposed: Measure calculasons based on the survey data for display on Hospice Compare. Find more about the CAHPS at the survey website,

7 CAHPS Hospice CAHPS survey will allow comparisons among hospices nasonally, once it is publicly reported. CMS believes: The data will help beneficiaries and their families to select a hospice program Public reporsng of survey results will encourage hospices to improve quality. CAHPS Proposed: PenalSes for the Hospice CAHPS Survey for the FY 2020, FY 2021, and FY 2022 annual payment updates. The Hospice CAHPS Survey is a component of the Hospice Quality ReporSng Program Quality Measure Concepts Under ConsideraSon for Future Years HEART PATIENT-ASSESSMENT TOOL Proposal: HEART pasent-assessment tool to evolve from HIS Hospice EvaluaSon & Assessment ReporSng Tool More in line with other post-acute care sehngs. IntegraSng a core standard data set into an assessment tool would allow hospices to use such a data set as the foundason for valid and reliable informason for pasent assessment, care planning, and service delivery. 27 7

8 CMS: We envision that pasent assessment data would be collected upon a pasent's admission to and discharge from any Medicare-cerSfied hospice provider; addisonal interim data collecson efforts are also possible. Will keep public informed of progress in developing HEART and will request input from hospice community. CMS s measure development contractor, RTI InternaSonal, has begun preliminary HEART development acsvises, including: ConducSng environmental scans and engaging clinical experts to determine which domains of care are important to capture in a hospice pasent assessment. PosSng a nasonal provider call and forming a Clinical CommiXee comprised of hospice organizasons from across the U.S. to parscipate in the early development of an assessment. CollaboraSng within CMS to assess various stakeholder needs and encourage collaborason within CMS and across other HHS agencies. Provide the quality data necessary for HQRP requirements and the current funcson of the HIS. Provide addisonal clinical data that could inform future payment refinements. Enable greater accuracy in quality reporsng. Decrease provider burden Help surveyors ensure hospices are meesng CondiSons of ParScipaSon and providing high quality pasent care. Inform payment refinement efforts of future. 8

9 Would not replace exissng requirements set forth in the Medicare Hospice CoPs (such as the inisal and comprehensive assessment). Would complement data collected as part of high-quality clinical care. Would replace the current HIS. Would not: Replace other HQRP data collecson efforts (that is, the CAHPS Hospice Survey). Would not replace regular submission of claims data. Imminent public hospice reporsng. HOSPICE COMPARE 34 Hospice Compare CMS: Hospice Compare site to launch late summer 2017 to inform customer choice. CAHPS Survey data to display on Hospice Compare in Hospice Compare CASPER system allows provider preview of data prior to public display. Hospice-Level Quality Measure Report. PaSent Stay-Level Quality Measure Report. 9

10 Hospice Compare HIS measures eligible for 2017 Hospice Compare: Treatment Preferences Beliefs/Values Pain Screening Pain Assessment Dyspnea Screening Dyspnea Treatment Bowel Regimen Hospice Compare Providers can preview their confidensal CASPER QM reports before public reporsng: Separate from public reporsng. For provider quality improvement. On-demand: Providers can compare their performance to the nasonal average for a reporsng period of their choice. References 2018 Hospice Proposed Rule at hxps:// CMS proposes updates to the wage index and payment rates for the Medicare Hospice Benefit for FY 2018, and releases Request for InformaSon at hxps:// Sheet-items/ html CMS Hospice Center at hxps:// Beth beth@noyceconsulsng.com From noyceconsulsng.com, click May 2017 Beth Noyce, RN, BSJMC, Hospice and Home Health Consultant HCS-H, HCS-D, COS-C, AHCC Advising board member 10