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CMS Proposes FY 2025 Hospice Payment Rule

Last week, the Centers for Medicare and Medicaid Services (CMS) issued its Fiscal Year (FY) 2025 proposed hospice rule relating to Medicare payment rates and the wage index for hospices serving Medicare beneficiaries.

The proposal includes a 2.6 percent increase ($705 million) in hospice per diems for 2025 over 2024 rates. CMS also updates the Routine Home Care (RHC), Continuous Home Care (CHC), Inpatient Respite Care (IRC), and General Inpatient Care (GIC) hospice Medicaid rates for FY 2025. The agency also proposes two new quality measures and 2025 implementation of the Hospice Outcomes and Patient Evaluation (HOPE) assessment tool to replace the Hospice Item Set.

The proposal also provides for the following additional changes:

  • In addition to the wage index, includes a proposal to adopt the most recent Office of Management and Budget (OMB) statistical area geographic delineations. This proposed change would have impacts on the payment rates hospices receive, based on their locations. Hospices affected by the change to their geographic wage index would be eligible for applying a 5 percent cap on any decrease to the wage index from the prior year.
  • Updates aspects of the hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey. This includes the addition of an email invitation to a web survey, with follow-up by mail to non-responders. It would also “shorten and simplify” the survey, according to CMS. It would also remove three nursing home items from the survey, revise the existing Hospice Team Communication and Getting Hospice Care Training measures, and add a new Care Preferences measure.
  • Proposes implementation of the HOPE tool, which was expected. It also proposes two new HOPE-based quality measures: Timely Reassessment of Pain Impact and Timely Reassessment of Non-Pain Symptom Impact.
  • Proposes an update to the Hospice Conditions of Participation (CoPs). CMS proposes to align Medicare hospice payment and CoP requirements by clarifying that the medical director; physician designee, if the medical director is unavailable; or a physician member of the hospice interdisciplinary group may review patient clinical information and certify a patient’s terminal illness.
  • Calls for a Request for Information (RFI) regarding future Hospice Quality Reporting Program (HQRP) Social Determinants of Health (SDOH) items.
  • Calls for an RFI around payment for high-intensity palliative care services.

Notably, the proposed rule does not include any program integrity provisions after recent activity to curb fraud and the surge in hospice growth in certain areas of the country.

The proposed rule can be viewed here in the Federal Register, and a CMS Fact Sheet is here.

Public comment on the proposal will be accepted until May 28, 2024.

For more information, please visit the CMS Hospice Center webpage here.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871