The 2022 Hospice Payment Proposed Rule from CMS

Spring is in the air! That means t-shirts, flowers, and everyone’s favorite: new rules from CMS! Let’s take a look at the 2022 Hospice Payment Rate Proposed Rule.

There’s good news for hospices on the payment front. The proposed rule increases payments by 2.3% for 2022. This increase is based on updates to the “hospital market basket,” the metric that CMS uses to estimate average costs for providers. As usual, hospices that fail to meet quality reporting requirements receive a two percent reduction to their annual market basket update. In order to reflect the payment increase, the annual cap amount has been adjusted proportionately. The proposed cap amount for 2022 is $31,389.66, 2.3% higher than 2021’s annual cap.

CMS is proposing changes to the Hospice CoPs (Conditions of Participation) for next year. In response to the coronavirus pandemic, CMS issued a waiver for hospice aide competency testing to allow for the use of pseudo-patients in place of real patients. CMS is proposing that this waiver, which is set to expire when the public health emergency (PHE) is over should be made permanent. This is a great step towards reducing provider burden, but as with any new rule there’s some give and take.

In addition, the proposed rule would require hospices to conduct a competency evaluation related to the deficient and related skills noted during a hospice aide supervisory visit. In theory, this would allow highly skilled aides to be trained quickly, but in practice that remains to be seen.

There are also updates to your hospice’s required public reporting and surveys. CMS is proposing a new measure in the HQRP called the Hospice Care Index. This single measure includes 10 indicators of quality that are calculated from claims data. According to CMS: “the indicators represent different aspects of hospice care and aim to convey a comprehensive characterization of the quality of care furnished by a hospice.” These quality indicators will cover the provision and timing of services, success in limiting “burdensome transitions” (discharges from hospice to hospital, for example), and the average rate of spending per patient.

Other important changes to your hospice’s public reporting include a proposed addition of the claims-based Hospice Visits in the Last Days of Life (HVLDL) measure. As the name implies, the public will be able to see how many visits were made in a patient’s final days. Another proposed change is the addition of your hospice’s CAHPS rating on Medicare Care Compare (formerly Hospice Compare). CMS also proposes the removal of the seven individual Hospice Item Set (HIS) measures since the Hospice Comprehensive Assessment Measure covers those items and is already public. CMS is also promising an update on the HOPE tool, although details are scarce as of this post. Stay tuned to our blog for more information as it becomes available.

As required by law, the 2022 Hospice Proposed Rule will be posted on the Federal Register with a public comment period beginning April 14, 2021. The voices of providers like you are critical in creating positive change and preventing burdensome regulations from becoming law. Take a look at let CMS know what you think!

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