CMS Final Rule 1675-F:  An Update to the Final FY 2018 Hospice Wage Index

On August 4th, CMS (Centers for Medicare & Medicaid Services) issued Final Rule CMS-1675-F , which will have an estimated economic impact of $180 million dollars in increased payments to hospice agencies during the Federal Fiscal Year (October 1, 2017 - September 30, 2018).

The final rule updates the hospice payment rates for fiscal year (FY) 2018, as required under section 1814(i) of the Social Security Act (the Act). The rule also discusses new quality measures and provides an update on the hospice quality reporting program (HQRP), consistent with the requirements of section 1814(i)(5) of the Act. In accordance with section 1814(i)(5)(A) of the Act, hospices that fail to meet quality reporting requirements receive a 2 percentage point reduction to their payments.

Below we have summarized some of the changes with the most impact.
The full rule can be found here.

Medicare Hospice Payment Update:
  • Hospice agencies that submit required quality data:
    • Medicare Hospice payments increased by 1%
    • Routine Home Care Payment Rates: October 1, 2017 - September 30, 2018:
      • Days 1-60:  $192.78
      • Days 61+:  $151.41
    • Other Hospice Payment Rates: Effective October 1, 2017
      • Continuous Home Care: $40.68 per hour; $976.42 for 24 hours
      • Inpatient Respite Care: $172.78
      • General Inpatient Care: $743.55
  • Hospice agencies that DO NOT submit required quality data:
    • Routine Home Care Payment Rates: October 1, 2017 - September 30, 2018
      • Days 1-60: $188.97
      • Days 61+: $148.41
    • Other Hospice Payment Rates: Effective October 1, 2017
      • Continuous Home Care $39.88 per hour, $957.08 for 24 hours
      • Inpatient Respite Care - $169.36
      • General Inpatient Care - $728.83
Hospice Cap Year Shifting to the Federal Fiscal Year:
Due to aligning the Hospice Cap Year with the Federal Fiscal Year, the self-reported Aggregate Cap Computation for Cap Year 2017 will be due February 28, 2018, five months after the cap year end.

The 2017 Hospice Aggregate Cap is $28.404.99 and Cap Year 2017 ends on September 30, 2017 for both Proportional and Streamlined. It is important to observe that the 2018 Hospice Aggregate Cap amount for Cap Year 2018 (October 1, 2017 - September 30, 2018) is now $28,689.09, an increase of $284.91 from Cap Year 2017.

Please see our previous Client Alert regarding the changes in the Cap Year dates.

Other Hospice Reporting Updates:
  • Hospice Quality Reporting:
    Extraordinary Circumstances Exemption and Extension - CMS has increased the time to request an exemption or extension due to extraordinary circumstances to 90 days, from the current 30 days. This will now apply to CAHPS (Consumer Assessment of Healthcare Providers and Systems), as well as the current HIS (Hospice Item Sent). This request must be sent via email.
  • Hospice CAHPS Survey based measures:
    Hospice COMPARE - CMS will begin reporting of all 8 measures on Hospice COMPARE, beginning in Winter 2018. These will be based on survey results for patients who died between April 1, 2015 to March 31, 2017, updated quarterly. Only hospices with 30 or more completed questionnaires during the reporting period will be displayed.
Potential Future Legislative Changes:
There are several potential future legislative changes such as ACA hospice reform, clinical information for determining terminal illness, adding social risk factors to HQRP, and Hospice Evaluation and Assessment Reporting (HEART), along with some potential new measures such as hospice care transitions and access to levels of hospice care.  Click here to learn more about these potential future changes.

We hope that you find this information valuable.  As always, we are here to help.  Feel free to contact us with any questions about these changes and how they impact your agency.

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