April 9, 2024 • 24 mins
Take a first look at the Fiscal Year 2025 Hospice Wage Index Rule with the unparalleled insights of industry authorities Katie Wehri (NAHC) and Patrick Harrison (NHPCO). Our conversation slices through the complexity to deliver a focused commentary on what this proposed rule signifies for hospice care providers, highlighting the rule's unexpected early release and the notable absence of anticipated program integrity proposals. We delve into the ramifications of the missing measures and the adaptability required in the wake of this development. The advent of the HOPE assessment tool is scrutinized as it transitions from a patient-centric assessment to a pivotal data collection asset, with an eye on the nuances of its rollout.
The hospice community stands at the precipice of change with the Medicare Advantage hospice component sunset within the VBID model by CMS. We dissect the repercussions of this pivot from earlier value-based system inclinations and emphasize the balance between cautious optimism and the realities of the evolving healthcare system. The episode also honors the dedication of hospice workers amid workforce tribulations and increased CMS scrutiny, championing a dual focus on patient care and compliance. We invite our listeners to deepen their engagement with this critical dialogue by leveraging resources such as NHPCO and NAHC, and by partaking in informative webinars that illuminate the path ahead. Your involvement and feedback are the heartbeat of our community, and we're thankful for every clinician's commitment to excellence in hospice care.
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
Hi there, I'm Jennifer Kennedy, the lead for
Compliance Standards and Qualityat CHAP, and welcome to our
CHAPcast.
Today we're going to be talkingabout the Fiscal Year 2025
Hospice Wage Index Rule.
This is in proposed format and,while we're not going to bring
(00:20):
you through each and everydetail of the rule because you
can get that out there invarious posts that have come out
from my respective guests todayand actually Chap did put out
an overview or a summary of therule as well but what we're
going to do here today is toreally, you know, do like a
(00:42):
quick snapshot of takeaways fromthese very talented hospice
experts in the hospiceregulatory and compliance space
that will help you get adifferent kind of perspective on
this particular rule.
So I am so pleased to be joinedby my colleagues and friends
(01:33):
today Katie Weary, who is theVice President of Regulatory
Affairs, quality and Complianceat the National Association for
Home Care and Hospice, andPatrick Harrison, who is the
Senior Director of Regulatoryand Compliance at the National
Hospice and Palliative CareOrganization.
Welcome to both of you.
(01:53):
I'm so happy to have you backin the saddle in the chap cast
saddle to tackle what we'regoing to talk about today.
Speaker 2 (02:02):
Well, thanks for having us, Jennifer.
It's always great to sit downand have a discussion with you
and Patrick.
Speaker 3 (02:09):
And Jennifer appreciate the opportunity.
It's great to be here todaywith you.
I know.
Speaker 1 (02:13):
So let's get down to brass tacks and talk about some
hospice, should we?
I always say, I love the smellof the Federal Register in the
morning.
I love it.
So I was actually prettysurprised to see when this rule
did post.
I was expecting it to postmaybe at the end of the month
(02:35):
Usually it's Friday at a 4o'clock posting time but when it
did pop out late on a Thursdayit did kind of take me by
surprise.
You know, I was a littleunaware.
But of course, as both of youknow, what we do is we see that
rule and pop it right open andwe say, oh, what's the page
count?
That's not bad.
(02:56):
Or oh my God, that's pretty bad.
Speaker 2 (02:59):
That's exactly right, and it was a little bit of a
surprise this year, just becauseyou know we're looking all the
time to see when it leaves theOffice of Management and Budget,
and it didn't leave until rightbefore it posted.
So it was a little bit of asurprise but honestly I'm
grateful that it was a Thursdayand not a Friday.
Speaker 1 (03:17):
Yeah, absolutely.
Speaker 2 (03:18):
I agree.
Speaker 1 (03:19):
Yeah, and you know I saw it.
Of course, when I saw it, asyou and Patrick probably did,
you know it was posted on thepublic inspection desk first,
and now it is, as of April 4th,made its way to the Federal
Register proper.
So you know, I really want tohear from you.
As I said, we're not going tolike go through the whole rule,
(03:41):
you know, do an account ofeverything that's in it.
But I wanted to know from youand let's start with Patrick
what was your number onetakeaway from this proposed rule
.
Speaker 3 (03:53):
So, jennifer, that is a great question and I'll be
perfectly honest, I'm going tocheat a little bit in my
response.
Okay, I'm going to say my keytakeaway for what was in the
rule and what was not in therule, and let me begin by first
stating what I think wassurprising to me as to what was
not in the rule, and that wasany program integrity proposals.
We all know that there'shospice is a space where we
(04:16):
actually are seeing fraudoccurring.
The NHPC, nac and the combinednational associations worked
very diligently and aggressivelyto protect and preserve the
quality and integrity of thehospice benefit in response to
some of the concerns we've seenout there about this fraud and
(04:38):
we saw some provisions last yearcome out about this and given
the pressure and given thescrutiny right now, it was very
surprising not to see anythingthere.
Possibly may see something yetin the home health rule later
this year, but just it wasinteresting to see at 4.15 pm on
Thursday nothing there poppedout in the rule.
Getting more to your question asto what kind of our key
(05:00):
takeaway was in the hospice rule, there's a lot of things but
really in terms of the keytakeaway was, I think, the hope
assessment and I.
There's a lot of items therethat are obviously important and
I don't think Hope's proposalis surprising, but it is
interesting to see this come out.
We finally have something here.
(05:21):
We have finally something wecan see, given the previous
years of discussion, workinggroups and listening sessions
that have been put together tohelp inform this assessment, and
I say assessment therepurposefully, this assessment
and I say assessment therepurposefully and it's
interesting given how thisstarted really as a patient
assessment tool, we've now movedaway from that in the role more
(05:42):
to a data collection instrument, which is interesting.
Another thing I'll flag is atiming here.
The fact sheet for the proposedrule indicated that this
assessment or this tool would gointo effect in fiscal year 2025
.
If you actually look in therule, it says on or after
(06:03):
October 1, 2025, which istechnically fiscal year 2026.
So just in terms of timingthere, it's going to be
interesting and very importantfor providers to take a look at
that and prepare for what'scoming next important for
providers to take a look at thatand prepare for what's coming
next.
Speaker 1 (06:20):
Yeah, you know the HOPE tool stood out to me
because you know I've beenwaiting with bated breath to see
what that draft tool looks like.
And you know it's very timely,patrick, because my colleague
Kim Skehan and I recorded awebinar for the NHPCO
Interdisciplinary Conference ongetting ready for the HOPE
assessment and I think we saidin there we predict that it's
(06:41):
going to post in this, you knowupcoming rulemaking and poof,
there it was.
So I agree with you.
Not too surprising, katie.
Number one standout in the rule.
Speaker 2 (06:53):
And to pick just one, that was difficult I know,
Absolutely stand out in the roleand to pick just one, that was
difficult.
I agree with everything thatPatrick has said so far and
definitely I was very intriguedwith the hope and wanted to
learn a little bit more aboutthat.
But I think the other part tothis is the RFI, or the request
for information on the highintensity, pallensity palliative
(07:15):
care services and really what'shappening.
There is a telltale sign thatCMS is looking at changing the
payment structure for hospice.
They're asking specifically isthere maybe another payment
methodology that we need to belooking at here in addition to
(07:36):
the hospice per diem rate?
That's going to help cover this, and I think that's great.
We have so many hospices thatfind it's incredibly difficult
to cover some of these highintensity services and they have
to limit the number of patientsthey can take with that, and
(07:56):
it's also a sign that CMS islooking at how hospices operate
and what is our healthcaresystem today and modernizing the
hospice benefit a bit, and Ithink that's great.
Speaker 1 (08:13):
Did you feel, katie, when you read that, like I got
like this, my back neurons weretingling like, oh, palliative
care.
We're thinking about palliativecare here, even though it's not
expressly said in in that text.
You know, it seems like they're.
You know, with the MM.
I'm sorry, I'm thinking it'sFriday and we're recording this
(08:37):
on a Friday, and sometimes myneurons are a little fried by
Friday.
But you know the demo that wehad, you know, over several
years to test palliative care tome.
There was something in therethat said to me oh you know,
maybe they're taking some ofthat outcome of data to think
(08:58):
about how they would, as youmentioned, reconstruct not only
the payment but maybereconstruct the benefit a little
bit.
Speaker 2 (09:08):
I definitely think that CMS is looking at the
benefit as a whole and ways thatthey can improve and expand
upon what is already existing.
As far as palliative careitself is concerned, I think
this RFI from CMS, as well asthe way that they're approaching
palliative care, is toincorporate palliative care
(09:30):
concepts into already existingprograms.
They're looking at seriouslyill individuals and really
expanding that palliative care,making sure that all programs
cover it, which is really whatis intended.
In palliative care it's notspecific to a time frame or to a
particular diagnosis.
(09:51):
So I think that part is great.
But I agree with you.
Hearkening back to the MedicareCare Choices model and other
models under CMMI, you knowthey're definitely recognizing
that our health care systemtoday needs to expand in its
(10:11):
payment structure to match thetypes of care that people are
receiving.
Speaker 1 (10:18):
Yeah, and their wishes for that care.
I couldn't agree with you more,katie.
I've been a hospice nurse for along time and I had the
absolute honor to be included inthe 2020 St Christopher's
Palliative Care Nursing Projectand talk to nurses all over the
globe, and it's palliative caremeaning seriously ill till you
(10:40):
take your last breath, andthat's the continuum.
And I would love to see the USsort of move in terms of
clinical care to something likethat, as a model for sure.
Speaker 2 (10:52):
Definitely.
Speaker 1 (10:53):
So let me come back to you, patrick Now, given what
we're seeing here in thisproposed rule and knowing what
we know about when it you knowmany of the things that went
into contact, contact went intoeffect rather on January 1st.
As you mentioned programintegrity, we had many program
integrity items go into effectJanuary 1st.
(11:16):
What do you see, or what willwhat in your crystal globe,
patrick?
Would you say the hospicelandscape looks like for the
balance of 2024, going intoearly 25?
Speaker 3 (11:32):
That's a great question, jennifer, and actually
one I get all the time now, andmy response is actually to
adopt the old sailors of Dodgehere Red skies at night, sailors
delight, red skies in themorning, sailors warning.
And I think the question rightnow is is it morning or night?
Speaker 1 (11:49):
Yeah.
Speaker 3 (11:50):
And there are definitely strong clouds on the
horizon and there's going to besome turbulent waters ahead that
we're going to have to navigatethrough this next year, and
there's a couple of things Ireally want to highlight that I
think is going to be importantfor us to be cognizant of as we
come to this new hospicelandscape.
A couple of things here, firstof which is the Hospice Special
(12:13):
Focus Program here, first ofwhich is the hospice special
focus program.
We know this was finalized inlast year's home health role and
we know CMS has indicated thathospices selected for the
special focus program will beidentified in November this year
.
The special focus program justfor the listeners here is a
program that was authorizedunder statute that is intended
(12:37):
to address hospices that havesubstantially failed to meet
Medicare program requirements.
There's been some discussionsaround that and back in with the
2022 home health rule, therewere some initial proposals
there that CMS openly did notfinalize.
At that time.
(12:58):
There was a technical expertpanel and then we saw in the
2024 home health final rule, cmsactually proposed and finalized
the methodology for the specialfocus program, or SFP, as you
may hear me refer to on thispodcast.
We are concerned about themethodology that CMS has
(13:23):
selected in identifying thosehospices and we are concerned
that will not effectivelyidentify hospices who may not be
providing care at a level theyshould be and, more importantly,
it may end up actually steeringbeneficiaries away from
hospices to potentially evenpoor performing hospices, and
that's something we're veryconcerned about.
Given that announcement, weknow that CMS will identify
(13:46):
those hospices for the specialfocus program itself, but CMS
will also identify the bottom10% of hospices nationwide under
that methodology and that canhave significant ramifications
for the industry going forward.
Other items I want to highlighthere as well, and there's a lot
.
I can spend just an hour onthis question alone, but I won't
(14:07):
do that to our listeners today.
Speaker 1 (14:08):
I know we could talk for hours, right.
Speaker 3 (14:13):
The other item I want to highlight here is VBID and
the value-based insurance designmodel.
As we all know, traditionallyMedicare is carved out of
Medicare Advantage and there hasbeen a hospice component of the
value-based insurance designmodel that's been in effect
since 2021.
Indicated that hospicecomponent would be sunset at the
(14:35):
end of this year, which is avery stark contrast from the
signaling that we were receivingfrom the agency even in January
, where, at that time, we had arequest for information
indicating that CMS planned toallow Medicare Advantage
organizations to require theenrollees to only receive
(14:58):
receive hospital services fromin-network providers.
And given that shift in theplans to really move towards
this value-based system and inrecognition that our nation is
going with Medicare Advantage,it was a little bit surprising
to see CMS's decision in thatarea.
Speaker 1 (15:11):
Yeah, it was.
I think a lot of people aresurprised but they're going shoo
.
But I don't think we should goshoo just yet, honestly, right.
Speaker 3 (15:20):
Absolutely, and I always say cautious optimism.
But it's are gone, but notforgotten it's.
We don't.
We know it's being sunset.
We're not, yeah sure, and I'mfrankly not even sure the CMS
knows yet what we're going to belooking for.
Yeah, I agree, yeah.
Speaker 1 (15:36):
I agree for sure.
All right, Katie, let's comeover to your crystal ball.
And what is your crystal ballsaying for hospice landscape?
Speaker 2 (15:45):
Well, definitely agree with Patrick.
We're not sure exactly howcloudy and stormy things are
going to be, but I definitelythink we're kind of looking at
hospice warning as opposed toSailor's delight here.
And as you talk about VBID andlike you both said, we cannot
just say, oh, it's all gone, wedon't need to worry about it
(16:06):
anymore.
Cms is focused on value-basedcare and they're also focused on
prior authorization.
How exactly hospice fits inthere, I think they don't know,
and that's why we saw a changein VBID.
But thinking about those goalsthat CMS has with value-based
(16:27):
purchasing and priorauthorization and where hospice
is today, in the recent past,and where there's really you
know, you know a flame actuallyunder CMS is related to program
integrity.
And could some of CMS's goalsfor value-based purchasing and
(16:47):
prior authorization, combinedwith program integrity, bring
something very new to hospices,like a review choice
demonstration where they'rehaving a review of the record
before payment is made to makesure that this patient is
eligible?
I think that is a definitepossibility and we need to
(17:09):
consider what CMS might be doingthat's innovative and different
than what we've heard about forhospices in the past or what
we've even thought was a realmof possibility for hospices in
the past, or what we've eventhought was a realm of
possibility for hospices in thepast.
Speaker 1 (17:22):
Yeah, I agree, Katie.
I think everything and anythingis on the table at this point
with the amount of scrutiny thatis happening.
So, katie, let's stick with you.
What is the number one actionthat you think providers should
be taking, like, let's say,right now?
Speaker 2 (17:37):
Right.
Well, I think this even relatesto kind of what I think is
something that will be achallenge for hospices for a
while and that is related to theworkforce.
You know we were seeing someworkforce challenges, especially
with nursing, prior to thepandemic, and the pandemic has
really impacted all of healthcare.
(18:00):
We're seeing vacancy rates innursing at, you know, 10, 15
percent vacancy rates across allhealth care providers, upwards
of 20, 25 percent.
So we know that that willremain a challenge that's going
to stay in our landscape and weneed to make sure to acknowledge
that and figure out how best todeal with that.
(18:22):
I think there are some.
If we're looking at silverlinings, one of the silver
linings is that necessity is thefather of invention.
I think that's how that sayinggoes and we may see some
innovative work that ourhospices are doing to address
that workforce challenge.
We've got to continue dealingwith the program integrity
(18:45):
issues, as we've talked abouthere.
We've got the special focusprogram.
We know that we have theprogram integrity.
All those themes are stillgoing to keep pulling through
and while they can't beminimized, they're incredibly
important.
You've got to have folks in yourorganization who are working on
all of those things, andthere's a lot to keep your eye
(19:08):
on, but what cannot be minimizedand, in fact, I think needs to
take center stage and I alwaystake this opportunity to remind
people of this, and I think,jennifer, you know we've talked
about this in some of our otherpodcasts is that focus on
patient care.
Absolutely, we absolutely haveto make that the center point,
(19:29):
and I'm not saying at theexpense of all these other
things that we've talked about,but you've got to have people in
your organization who arechampioning that focus on
patient care and improvingquality of care and looking at
tools like the HOPE and othertools that are out there.
How can we improve the servicesthat we're delivering?
(19:52):
And I just think that's a verycritical message that we cannot
lose.
Speaker 1 (19:56):
Absolutely Katie Patrick.
Number one action AbsolutelyKatie Patrick number one action.
Speaker 3 (20:01):
First off, I agree with Katie 100 percent there.
Absolutely Excellent pointthere.
And really that North Star.
We need to keep our minds onheads as we move forward through
this.
Other item I'll mention here isgoing to be critical, now more
than ever, really to beproactive and engaged rather
than being reactive.
And what I mean by that isactually a couple of things,
(20:28):
First of which is it's going tobe really important to stay
engaged in federal issues, be itcongressional, be it regulatory
.
There is a lot happening in thehospice space right now between
quality changes, between specialfocus, program program
integrity and otherwise.
It's really critical that weare all paying close attention,
not just to see what's happeningright now, but what's coming
(20:50):
down the line and part.
One particular component I'drecommend there is, with this
rule proposal coming out andobviously this is not the final
rule, there may be changes butreally HUSP should take a look
and understand this HOPE tooland what that's going to mean,
how we're going to be measuring,how we're going to be
conducting these assessments,because once that's finalized,
(21:12):
there are going to be some, Isay, challenges and
opportunities there to getsystems up to date to manage
that change In the rule.
We also see some significantwage index area changes and
among other changes the officesreally need to be aware of,
because some of those changescould have the impact of
changing certain regions'payments For example, your
(21:33):
classification from an urban torural or vice versa, which, if
finalized, will have significantimplications for payments.
We talked earlier about thespecial focus program.
Katie talked a bit about theprogram integrity considerations
and these are all things thatwe really need to be paying
close attention to, and I knowus policy wonks like to look at
(21:55):
these federal rules, and earlieryou made the comment, Jennifer,
about looking at the FederalRegister, and I agree I'm one of
those policy nerds there too,but I think it's also important
that hospices do the same aswell.
Another item I'll just mentionas part of that piece and I know
I'm getting a littlelong-winded in my response here,
Jennifer, so apologies, butpart of that engagement, it's
(22:18):
important to see where CMS isgoing and one of the directions
that CMS is going is healthequity.
We know it's one of the agencypillars.
We've seen efforts to addressdisparities and advance equity
and various rulemaking proposalsand policies throughout the
(22:40):
care continuum and as we beginlooking at data and looking at
how CMS plans to address thatwithin a hospice and productive
care lens.
To the extent hospices can bepart of that conversation, I
think it's going to be verycritical going forward.
Speaker 1 (22:50):
Yeah, I couldn't agree with you more, patrick, on
that.
In fact, chap is rolling out ourhealth equity standards of
excellence later this yearbecause we feel that it is an
important, important thing toaddress and it's extremely
timely as well.
(23:10):
Well, oh my gosh, thank you bothfor joining me today to give
your expert thoughts to ourlisteners, and I wanted to thank
all of you for taking time outof your day to plug into our
podcast.
So, from me and the entire CHAPteam, and before I do sign off,
there are a couple importantthings that we would ask you, I
(23:32):
think collectively, as Katie,patrick and Jennifer from CHAP
today, from chap today, is youknow, plug into what knock and
nhpco have in terms of their um,their summaries for the final
rule that they put out, whichare equally excellent um.
And also, I know that you will,if you haven't already been,
(23:53):
facilitate you will facilitatewebinars that produce a summary
and an overview for folks toplug into as well.
And please, from CHAP, we wouldlove you to leave a review,
share the podcast link so thatit can make its way to more
people who can learn about whatis included not only in the
(24:15):
hospice rule in proposed format,but what we think the landscape
is going to look like incalendar year 2024.
And for me and the entire CHAPteam, keep your quality needle
moving forward, stay safe andwell and thanks for all you do.
Thank you.
Hi there, I'm Jennifer Kennedy, the lead for
Compliance Standards and Qualityat CHAP, and welcome to our
CHAPcast.
Today we're going to be talkingabout the Fiscal Year 2025
Hospice Wage Index Rule.
This is in proposed format and,while we're not going to bring
(00:20):
you through each and everydetail of the rule because you
can get that out there invarious posts that have come out
from my respective guests todayand actually Chap did put out
an overview or a summary of therule as well but what we're
going to do here today is toreally, you know, do like a
(00:42):
quick snapshot of takeaways fromthese very talented hospice
experts in the hospiceregulatory and compliance space
that will help you get adifferent kind of perspective on
this particular rule.
So I am so pleased to be joinedby my colleagues and friends
(01:33):
today Katie Weary, who is theVice President of Regulatory
Affairs, quality and Complianceat the National Association for
Home Care and Hospice, andPatrick Harrison, who is the
Senior Director of Regulatoryand Compliance at the National
Hospice and Palliative CareOrganization.
Welcome to both of you.
(01:53):
I'm so happy to have you backin the saddle in the chap cast
saddle to tackle what we'regoing to talk about today.
Speaker 2 (02:02):
Well, thanks for having us, Jennifer.
It's always great to sit downand have a discussion with you
and Patrick.
Speaker 3 (02:09):
And Jennifer appreciate the opportunity.
It's great to be here todaywith you.
I know.
Speaker 1 (02:13):
So let's get down to brass tacks and talk about some
hospice, should we?
I always say, I love the smellof the Federal Register in the
morning.
I love it.
So I was actually prettysurprised to see when this rule
did post.
I was expecting it to postmaybe at the end of the month
(02:35):
Usually it's Friday at a 4o'clock posting time but when it
did pop out late on a Thursdayit did kind of take me by
surprise.
You know, I was a littleunaware.
But of course, as both of youknow, what we do is we see that
rule and pop it right open andwe say, oh, what's the page
count?
That's not bad.
(02:56):
Or oh my God, that's pretty bad.
Speaker 2 (02:59):
That's exactly right, and it was a little bit of a
surprise this year, just becauseyou know we're looking all the
time to see when it leaves theOffice of Management and Budget,
and it didn't leave until rightbefore it posted.
So it was a little bit of asurprise but honestly I'm
grateful that it was a Thursdayand not a Friday.
Speaker 1 (03:17):
Yeah, absolutely.
Speaker 2 (03:18):
I agree.
Speaker 1 (03:19):
Yeah, and you know I saw it.
Of course, when I saw it, asyou and Patrick probably did,
you know it was posted on thepublic inspection desk first,
and now it is, as of April 4th,made its way to the Federal
Register proper.
So you know, I really want tohear from you.
As I said, we're not going tolike go through the whole rule,
(03:41):
you know, do an account ofeverything that's in it.
But I wanted to know from youand let's start with Patrick
what was your number onetakeaway from this proposed rule
.
Speaker 3 (03:53):
So, jennifer, that is a great question and I'll be
perfectly honest, I'm going tocheat a little bit in my
response.
Okay, I'm going to say my keytakeaway for what was in the
rule and what was not in therule, and let me begin by first
stating what I think wassurprising to me as to what was
not in the rule, and that wasany program integrity proposals.
We all know that there'shospice is a space where we
(04:16):
actually are seeing fraudoccurring.
The NHPC, nac and the combinednational associations worked
very diligently and aggressivelyto protect and preserve the
quality and integrity of thehospice benefit in response to
some of the concerns we've seenout there about this fraud and
(04:38):
we saw some provisions last yearcome out about this and given
the pressure and given thescrutiny right now, it was very
surprising not to see anythingthere.
Possibly may see something yetin the home health rule later
this year, but just it wasinteresting to see at 4.15 pm on
Thursday nothing there poppedout in the rule.
Getting more to your question asto what kind of our key
(05:00):
takeaway was in the hospice rule, there's a lot of things but
really in terms of the keytakeaway was, I think, the hope
assessment and I.
There's a lot of items therethat are obviously important and
I don't think Hope's proposalis surprising, but it is
interesting to see this come out.
We finally have something here.
(05:21):
We have finally something wecan see, given the previous
years of discussion, workinggroups and listening sessions
that have been put together tohelp inform this assessment, and
I say assessment therepurposefully, this assessment
and I say assessment therepurposefully and it's
interesting given how thisstarted really as a patient
assessment tool, we've now movedaway from that in the role more
(05:42):
to a data collection instrument, which is interesting.
Another thing I'll flag is atiming here.
The fact sheet for the proposedrule indicated that this
assessment or this tool would gointo effect in fiscal year 2025
.
If you actually look in therule, it says on or after
(06:03):
October 1, 2025, which istechnically fiscal year 2026.
So just in terms of timingthere, it's going to be
interesting and very importantfor providers to take a look at
that and prepare for what'scoming next important for
providers to take a look at thatand prepare for what's coming
next.
Speaker 1 (06:20):
Yeah, you know the HOPE tool stood out to me
because you know I've beenwaiting with bated breath to see
what that draft tool looks like.
And you know it's very timely,patrick, because my colleague
Kim Skehan and I recorded awebinar for the NHPCO
Interdisciplinary Conference ongetting ready for the HOPE
assessment and I think we saidin there we predict that it's
(06:41):
going to post in this, you knowupcoming rulemaking and poof,
there it was.
So I agree with you.
Not too surprising, katie.
Number one standout in the rule.
Speaker 2 (06:53):
And to pick just one, that was difficult I know,
Absolutely stand out in the roleand to pick just one, that was
difficult.
I agree with everything thatPatrick has said so far and
definitely I was very intriguedwith the hope and wanted to
learn a little bit more aboutthat.
But I think the other part tothis is the RFI, or the request
for information on the highintensity, pallensity palliative
(07:15):
care services and really what'shappening.
There is a telltale sign thatCMS is looking at changing the
payment structure for hospice.
They're asking specifically isthere maybe another payment
methodology that we need to belooking at here in addition to
(07:36):
the hospice per diem rate?
That's going to help cover this, and I think that's great.
We have so many hospices thatfind it's incredibly difficult
to cover some of these highintensity services and they have
to limit the number of patientsthey can take with that, and
(07:56):
it's also a sign that CMS islooking at how hospices operate
and what is our healthcaresystem today and modernizing the
hospice benefit a bit, and Ithink that's great.
Speaker 1 (08:13):
Did you feel, katie, when you read that, like I got
like this, my back neurons weretingling like, oh, palliative
care.
We're thinking about palliativecare here, even though it's not
expressly said in in that text.
You know, it seems like they're.
You know, with the MM.
I'm sorry, I'm thinking it'sFriday and we're recording this
(08:37):
on a Friday, and sometimes myneurons are a little fried by
Friday.
But you know the demo that wehad, you know, over several
years to test palliative care tome.
There was something in therethat said to me oh you know,
maybe they're taking some ofthat outcome of data to think
(08:58):
about how they would, as youmentioned, reconstruct not only
the payment but maybereconstruct the benefit a little
bit.
Speaker 2 (09:08):
I definitely think that CMS is looking at the
benefit as a whole and ways thatthey can improve and expand
upon what is already existing.
As far as palliative careitself is concerned, I think
this RFI from CMS, as well asthe way that they're approaching
palliative care, is toincorporate palliative care
(09:30):
concepts into already existingprograms.
They're looking at seriouslyill individuals and really
expanding that palliative care,making sure that all programs
cover it, which is really whatis intended.
In palliative care it's notspecific to a time frame or to a
particular diagnosis.
(09:51):
So I think that part is great.
But I agree with you.
Hearkening back to the MedicareCare Choices model and other
models under CMMI, you knowthey're definitely recognizing
that our health care systemtoday needs to expand in its
(10:11):
payment structure to match thetypes of care that people are
receiving.
Speaker 1 (10:18):
Yeah, and their wishes for that care.
I couldn't agree with you more,katie.
I've been a hospice nurse for along time and I had the
absolute honor to be included inthe 2020 St Christopher's
Palliative Care Nursing Projectand talk to nurses all over the
globe, and it's palliative caremeaning seriously ill till you
(10:40):
take your last breath, andthat's the continuum.
And I would love to see the USsort of move in terms of
clinical care to something likethat, as a model for sure.
Speaker 2 (10:52):
Definitely.
Speaker 1 (10:53):
So let me come back to you, patrick Now, given what
we're seeing here in thisproposed rule and knowing what
we know about when it you knowmany of the things that went
into contact, contact went intoeffect rather on January 1st.
As you mentioned programintegrity, we had many program
integrity items go into effectJanuary 1st.
(11:16):
What do you see, or what willwhat in your crystal globe,
patrick?
Would you say the hospicelandscape looks like for the
balance of 2024, going intoearly 25?
Speaker 3 (11:32):
That's a great question, jennifer, and actually
one I get all the time now, andmy response is actually to
adopt the old sailors of Dodgehere Red skies at night, sailors
delight, red skies in themorning, sailors warning.
And I think the question rightnow is is it morning or night?
Speaker 1 (11:49):
Yeah.
Speaker 3 (11:50):
And there are definitely strong clouds on the
horizon and there's going to besome turbulent waters ahead that
we're going to have to navigatethrough this next year, and
there's a couple of things Ireally want to highlight that I
think is going to be importantfor us to be cognizant of as we
come to this new hospicelandscape.
A couple of things here, firstof which is the Hospice Special
(12:13):
Focus Program here, first ofwhich is the hospice special
focus program.
We know this was finalized inlast year's home health role and
we know CMS has indicated thathospices selected for the
special focus program will beidentified in November this year
.
The special focus program justfor the listeners here is a
program that was authorizedunder statute that is intended
(12:37):
to address hospices that havesubstantially failed to meet
Medicare program requirements.
There's been some discussionsaround that and back in with the
2022 home health rule, therewere some initial proposals
there that CMS openly did notfinalize.
At that time.
(12:58):
There was a technical expertpanel and then we saw in the
2024 home health final rule, cmsactually proposed and finalized
the methodology for the specialfocus program, or SFP, as you
may hear me refer to on thispodcast.
We are concerned about themethodology that CMS has
(13:23):
selected in identifying thosehospices and we are concerned
that will not effectivelyidentify hospices who may not be
providing care at a level theyshould be and, more importantly,
it may end up actually steeringbeneficiaries away from
hospices to potentially evenpoor performing hospices, and
that's something we're veryconcerned about.
Given that announcement, weknow that CMS will identify
(13:46):
those hospices for the specialfocus program itself, but CMS
will also identify the bottom10% of hospices nationwide under
that methodology and that canhave significant ramifications
for the industry going forward.
Other items I want to highlighthere as well, and there's a lot
.
I can spend just an hour onthis question alone, but I won't
(14:07):
do that to our listeners today.
Speaker 1 (14:08):
I know we could talk for hours, right.
Speaker 3 (14:13):
The other item I want to highlight here is VBID and
the value-based insurance designmodel.
As we all know, traditionallyMedicare is carved out of
Medicare Advantage and there hasbeen a hospice component of the
value-based insurance designmodel that's been in effect
since 2021.
Indicated that hospicecomponent would be sunset at the
(14:35):
end of this year, which is avery stark contrast from the
signaling that we were receivingfrom the agency even in January
, where, at that time, we had arequest for information
indicating that CMS planned toallow Medicare Advantage
organizations to require theenrollees to only receive
(14:58):
receive hospital services fromin-network providers.
And given that shift in theplans to really move towards
this value-based system and inrecognition that our nation is
going with Medicare Advantage,it was a little bit surprising
to see CMS's decision in thatarea.
Speaker 1 (15:11):
Yeah, it was.
I think a lot of people aresurprised but they're going shoo
.
But I don't think we should goshoo just yet, honestly, right.
Speaker 3 (15:20):
Absolutely, and I always say cautious optimism.
But it's are gone, but notforgotten it's.
We don't.
We know it's being sunset.
We're not, yeah sure, and I'mfrankly not even sure the CMS
knows yet what we're going to belooking for.
Yeah, I agree, yeah.
Speaker 1 (15:36):
I agree for sure.
All right, Katie, let's comeover to your crystal ball.
And what is your crystal ballsaying for hospice landscape?
Speaker 2 (15:45):
Well, definitely agree with Patrick.
We're not sure exactly howcloudy and stormy things are
going to be, but I definitelythink we're kind of looking at
hospice warning as opposed toSailor's delight here.
And as you talk about VBID andlike you both said, we cannot
just say, oh, it's all gone, wedon't need to worry about it
(16:06):
anymore.
Cms is focused on value-basedcare and they're also focused on
prior authorization.
How exactly hospice fits inthere, I think they don't know,
and that's why we saw a changein VBID.
But thinking about those goalsthat CMS has with value-based
(16:27):
purchasing and priorauthorization and where hospice
is today, in the recent past,and where there's really you
know, you know a flame actuallyunder CMS is related to program
integrity.
And could some of CMS's goalsfor value-based purchasing and
(16:47):
prior authorization, combinedwith program integrity, bring
something very new to hospices,like a review choice
demonstration where they'rehaving a review of the record
before payment is made to makesure that this patient is
eligible?
I think that is a definitepossibility and we need to
(17:09):
consider what CMS might be doingthat's innovative and different
than what we've heard about forhospices in the past or what
we've even thought was a realmof possibility for hospices in
the past, or what we've eventhought was a realm of
possibility for hospices in thepast.
Speaker 1 (17:22):
Yeah, I agree, Katie.
I think everything and anythingis on the table at this point
with the amount of scrutiny thatis happening.
So, katie, let's stick with you.
What is the number one actionthat you think providers should
be taking, like, let's say,right now?
Speaker 2 (17:37):
Right.
Well, I think this even relatesto kind of what I think is
something that will be achallenge for hospices for a
while and that is related to theworkforce.
You know we were seeing someworkforce challenges, especially
with nursing, prior to thepandemic, and the pandemic has
really impacted all of healthcare.
(18:00):
We're seeing vacancy rates innursing at, you know, 10, 15
percent vacancy rates across allhealth care providers, upwards
of 20, 25 percent.
So we know that that willremain a challenge that's going
to stay in our landscape and weneed to make sure to acknowledge
that and figure out how best todeal with that.
(18:22):
I think there are some.
If we're looking at silverlinings, one of the silver
linings is that necessity is thefather of invention.
I think that's how that sayinggoes and we may see some
innovative work that ourhospices are doing to address
that workforce challenge.
We've got to continue dealingwith the program integrity
(18:45):
issues, as we've talked abouthere.
We've got the special focusprogram.
We know that we have theprogram integrity.
All those themes are stillgoing to keep pulling through
and while they can't beminimized, they're incredibly
important.
You've got to have folks in yourorganization who are working on
all of those things, andthere's a lot to keep your eye
(19:08):
on, but what cannot be minimizedand, in fact, I think needs to
take center stage and I alwaystake this opportunity to remind
people of this, and I think,jennifer, you know we've talked
about this in some of our otherpodcasts is that focus on
patient care.
Absolutely, we absolutely haveto make that the center point,
(19:29):
and I'm not saying at theexpense of all these other
things that we've talked about,but you've got to have people in
your organization who arechampioning that focus on
patient care and improvingquality of care and looking at
tools like the HOPE and othertools that are out there.
How can we improve the servicesthat we're delivering?
(19:52):
And I just think that's a verycritical message that we cannot
lose.
Speaker 1 (19:56):
Absolutely Katie Patrick.
Number one action AbsolutelyKatie Patrick number one action.
Speaker 3 (20:01):
First off, I agree with Katie 100 percent there.
Absolutely Excellent pointthere.
And really that North Star.
We need to keep our minds onheads as we move forward through
this.
Other item I'll mention here isgoing to be critical, now more
than ever, really to beproactive and engaged rather
than being reactive.
And what I mean by that isactually a couple of things,
(20:28):
First of which is it's going tobe really important to stay
engaged in federal issues, be itcongressional, be it regulatory
.
There is a lot happening in thehospice space right now between
quality changes, between specialfocus, program program
integrity and otherwise.
It's really critical that weare all paying close attention,
not just to see what's happeningright now, but what's coming
(20:50):
down the line and part.
One particular component I'drecommend there is, with this
rule proposal coming out andobviously this is not the final
rule, there may be changes butreally HUSP should take a look
and understand this HOPE tooland what that's going to mean,
how we're going to be measuring,how we're going to be
conducting these assessments,because once that's finalized,
(21:12):
there are going to be some, Isay, challenges and
opportunities there to getsystems up to date to manage
that change In the rule.
We also see some significantwage index area changes and
among other changes the officesreally need to be aware of,
because some of those changescould have the impact of
changing certain regions'payments For example, your
(21:33):
classification from an urban torural or vice versa, which, if
finalized, will have significantimplications for payments.
We talked earlier about thespecial focus program.
Katie talked a bit about theprogram integrity considerations
and these are all things thatwe really need to be paying
close attention to, and I knowus policy wonks like to look at
(21:55):
these federal rules, and earlieryou made the comment, Jennifer,
about looking at the FederalRegister, and I agree I'm one of
those policy nerds there too,but I think it's also important
that hospices do the same aswell.
Another item I'll just mentionas part of that piece and I know
I'm getting a littlelong-winded in my response here,
Jennifer, so apologies, butpart of that engagement, it's
(22:18):
important to see where CMS isgoing and one of the directions
that CMS is going is healthequity.
We know it's one of the agencypillars.
We've seen efforts to addressdisparities and advance equity
and various rulemaking proposalsand policies throughout the
(22:40):
care continuum and as we beginlooking at data and looking at
how CMS plans to address thatwithin a hospice and productive
care lens.
To the extent hospices can bepart of that conversation, I
think it's going to be verycritical going forward.
Speaker 1 (22:50):
Yeah, I couldn't agree with you more, patrick, on
that.
In fact, chap is rolling out ourhealth equity standards of
excellence later this yearbecause we feel that it is an
important, important thing toaddress and it's extremely
timely as well.
(23:10):
Well, oh my gosh, thank you bothfor joining me today to give
your expert thoughts to ourlisteners, and I wanted to thank
all of you for taking time outof your day to plug into our
podcast.
So, from me and the entire CHAPteam, and before I do sign off,
there are a couple importantthings that we would ask you, I
(23:32):
think collectively, as Katie,patrick and Jennifer from CHAP
today, from chap today, is youknow, plug into what knock and
nhpco have in terms of their um,their summaries for the final
rule that they put out, whichare equally excellent um.
And also, I know that you will,if you haven't already been,
(23:53):
facilitate you will facilitatewebinars that produce a summary
and an overview for folks toplug into as well.
And please, from CHAP, we wouldlove you to leave a review,
share the podcast link so thatit can make its way to more
people who can learn about whatis included not only in the
(24:15):
hospice rule in proposed format,but what we think the landscape
is going to look like incalendar year 2024.
And for me and the entire CHAPteam, keep your quality needle
moving forward, stay safe andwell and thanks for all you do.
Thank you.
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