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CMS Hospice Payment Update

Robin's Blog
Thought Leadership

By Robin Stawasz

CMS recently released their annual payment adjustment for the CMS Hospice Benefit. Especially during this time of change and upheaval in healthcare, it is hard to predict what direction CMS will go. However, CMS did propose a 2.8% increase in the reimbursement rate and in the aggregate payment cap. This was despite MedPAC’s recommendation to CMS to deeply cut the aggregate payment cap in light of large operating margins hospices are realizing on average.

CMS is also moving to make the ability to perform recertification visits by telehealth permanent after putting this in place temporarily in response to the COVID-19 emergency. This gain in efficiency is a welcome process improvement. CMS also provided an update on the new HOPE tool in development and spoke of instituting future quality measures focused on equity. For those hospices not submitting their quality scores, their reimbursement rate reduction would move from a 2% cut to a 4% cut. This should further push hospices to increase their focus on standardized social and equity factor screenings and interventions, which is already necessary to provide the highest quality of care and to be competitive in the value-based contracting market.

CMS is continuing to focus on addressing fraud, waste, and abuse by hospices – a priority echoed by many industry advocacy groups such as NHPCO, NAHC, and Leading Age. In this Payment Update, CMS is proposing the requirement that any physician who orders or certifies hospice services for a Medicare beneficiary must be enrolled in Medicare or validly opted-out, or the hospice period of care will not be covered. They also speak of additional oversight efforts to come. While such increased regulations can come with their own complications, the need to better police the field is tantamount.

CMS is asking for public comments on this proposal by May 30, 2023. If you have any concerns or comments for CMS, please do not hesitate to reach out to them. The path to do so is included in the source material listed below.

If you would like to talk more about the CMS Hospice Benefit, Acclivity is here for you – please contact us.

Source Material: “Fiscal Year (FY) 2024 Hospice Payment Rate Update Proposed Rule (CMS-1787-P)” posted by CMS on March 31, 2023, and available at https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2024-hospice-payment-rate-update-proposed-rule-cms-1787-p  

Robin Stawasz