In the Final Rule released and now in effect, CMS had some notable concerns about hospice providers which will be the subject of increased scrutiny. As time goes on, hospices should be correcting any internal issues and be prepared for possible review by CMS.
End of Life Visits
As the end of a patient’s life nears, CMS is concerned that hospices are continuing to provide the same level of care as they did through the entire episode. CMS would like to see this change and would like hospices to devote more time and resources to care at the end of a patient’s life when the intensity and need is present.
Providers should expect to receive ADRs for the purpose of reviewing and enforcing this shift in services within the next year. Hospices must align visits and services to coincide with end of life care, showing an increase in volume during this period. Starting in FY 2019, providers are going to be required to include data on imminent death visits.
CMS is concerned that double dipping could be occurring for patient medications. As drug costs are supposed to be borne by the hospice provider, CMS is worried that patients are still utilizing their Part D drug benefit to receive everyday medications rather than the hospice picking up the tab. Going forward, we can be sure that CMS will be targeting hospices to ensure compliance.
Hospice providers are required to now inform patients that the care they receive when electing hospice could be reviewed for necessity. A quality improvement organization (QIO) will be named to lead this effort and review the needs of the patient. Should a concern arise, the QIO will contact the patient and then the hospice provider will need to act as the intermediary between QIO and the patient to explain and prove the need.
Spending and Budgets
CMS is concerned about hospice in general and will likely begin to look at operating margins, and the profits earned by hospices. Some hospice agencies continually generate very high profit margins while others are barely breaking even or have a light margin. This spending has caught the attention of law makers and CMS. In the future, hospices should expect that reimbursement will not be as generous and year after year increases in reimbursement may not be likely.
Physician assistants, as of January 1, 2019 will be recognized as a designated attending hospice physician. PAs must continue to practice within the allowed scope of their state’s licensure parameters. PAs, however, cannot certify or recertify terminal illness, conduct face to face encounters, and cannot replace a medical doctor in a hospice IDT meeting.
Other Important News
There are no new quality reporting measures for this fiscal year. However, that will change for 2020.
Hospices are going to continue to be required to report HIS and CAHPS data. Failure to do so will result in a 2% reimbursement reduction and likely additional scrutiny.
While the current fiscal year has begun, there is so much to do for providers to stay in compliance and be ready.
The past month has been a whirlwind of activity for providers and should be continuing to be busy throughout the upcoming months. During this time, we will continue to provide guidance and tips to help your agency perform well clinically, operationally, and financially! Let’s make the upcoming year better for everybody!