Navigating the CMS FY 2025 Final Hospice Payment Rule
Author: Maxwell Healthcare Associates
Posted: August 6, 2024
Unpacking the FY 2025 Hospice Payment Final Rule [MHA Corner Podcast]
On July 30, 2024, the Centers for Medicare & Medicaid Services (CMS) released the final rule (CMS-1810-F) for Fiscal Year (FY) 2025. The FY 2025 final rule brings several updates aimed at enhancing care quality, addressing social determinants of health, and ensuring financial stability for hospice providers. Overall, the rule comprises payment rate updates, wage index changes, and new reporting tools aimed at increasing the quality and success of hospice initiatives.
Medicare Hospice Payment Policies
Payment rate updates and aggregate cap
The FY 2025 hospice payment update is set at 2.9%, reflecting an estimated increase of $790 million in payments from FY 2024. This increase arises from a 3.4% inpatient hospital market basket percentage increase, reduced by a 0.5 percentage point productivity adjustment. The updated payment rate underscores CMS's commitment to equitable reimbursement while acknowledging the operational challenges faced by hospice providers.
Additionally, the statutory aggregate cap for hospices is set at $34,465.34 for FY 2025, an increase from $33,494.01 in FY 2024. This cap limits the overall payments per individual to a hospice annually, providing a financial safeguard for both providers and patients.
Geographic wage index changes
A significant aspect of the final rule is the adoption of the most recent Office of Management and Budget (OMB) statistical area delineations, revising the core-based statistical areas (CBSA) based on the 2020 Decennial Census data. To mitigate potential financial strain, hospices negatively impacted by these changes will experience a maximum 5% reduction to their geographic wage index. This permanent cap prevents any area’s wage index from falling below 95% of its prior fiscal year calculation, providing stability and predictability in wage adjustments.
Hospice Quality Reporting Program (HQRP)
Introduction of the HOPE Instrument
The FY 2025 final rule introduces the Hospice Outcomes and Patient Evaluation (HOPE) instrument, set to replace the existing Hospice Item Set (HIS). This new patient-level data collection tool will be implemented beginning FY 2025 and will gather data at multiple points across a patient’s hospice stay, including admission, updates, and discharge.
The HOPE instrument expands data collection to include new domains, such as:
- Sociodemographic Information (updated)
- Expanded Diagnoses
- Symptom Impact Assessment
- Skin Conditions
- Imminent Death Indicators
These enhancements will provide CMS with a more comprehensive understanding of patient experiences, improving quality of care delivery.
New quality measures
The rule finalizes two new process measures for the HQRP: Timely Follow-up for Pain Impact and Timely Follow-up for Non-Pain Symptom Impact, both expected to commence in FY 2028. These measures focus on whether a follow-up visit occurs within 48 hours of an assessment revealing moderate or severe symptom impact, ensuring prompt and effective care responses.
Social Determinants of Health (SDOH) and health equity
In alignment with CMS’s broader commitment to health equity, the rule explores the integration of social determinants of health (SDOH) elements into quality reporting. Public feedback on potential SDOH data collection—such as housing instability, food insecurity, utilities, and transportation challenges—will shape future quality measures and public reporting requirements.
Tom Maxwell and Jay Duty Discuss the FY 2025 Hospice Payment Final Rule
Consumer Assessment of Healthcare Providers and Systems (CAHPS) Hospice Survey
The final rule introduces significant modifications to the CAHPS Hospice Survey to enhance patient feedback mechanisms. These include:
- Addition of a Web-Mail Mode: A new survey modality involving an email invitation followed by a mail survey to non-responders.
- Survey Shortening and Simplification: Changes to streamline the survey process and improve response rates.
- Revised Administration Protocols: Implementation of a pre-notification letter and an extension of the field period from 42 to 49 days.
- New Care Preferences Measure: A two-item measure focusing on patient care preferences.
- Revised Hospice Team Communication and Hospice Care Training Measures: Enhancements based on recent survey experiments.
- Removal of Three Nursing Home Items: Adjustments to align with broader survey improvements.
These changes aim to modernize data collection, ensuring that patient voices are integral to hospice care delivery improvements.
Clarifications and technical corrections
The final rule addresses discrepancies in the Conditions of Participation (CoPs) related to the medical director, physician designee, and interdisciplinary group (IDG) roles. The clarified regulations align the medical director CoP and hospice payment requirements, enhancing clarity and consistency.
Furthermore, technical updates to the hospice Conditions of Participation (CoPs) address language discrepancies, aligning operational protocols with overarching regulatory frameworks. Clarifications related to the election statement and notice of election (NOE) further distinguish the requirements for each, improving comprehension and compliance.
Additionally, CMS corrected a technical error, replacing “marriage and family counselor” with “marriage and family therapist” in the hospice personnel requirements, ensuring accuracy in professional designations.
The MHA Difference - Strategic Solutions
As the hospice landscape continues to evolve, staying ahead of regulatory changes is crucial for maintaining compliance and delivering high-quality care. At Maxwell Healthcare Associates (MHA), our team of experts is dedicated to helping agencies navigate these complexities with confidence and ease.
Our comprehensive due diligence assessments and tech-enabled solutions, such as NOTIFYnana and nanaBEREAVEMENT, empower agencies to meet the demands of changing regulations and drive meaningful improvements in patient care and caregiver satisfaction. If you’re ready to adapt to these changes and enhance your agency’s success, contact us at [email protected] or visit www.maxwellhca.com.
Want to learn more about the CMS FY 2025 Hospice Payment Final Rule? Listen to MHA's own Tom Maxwell and Jay Duty discuss on the MHA Corner Podcast: