Transcript Power Point presentation - National Hospice and Palliative Care

Components Of FY2014 Proposed Hospice
Wage Index Rule – Posted April 29, 2013
Hospice Wage Index And Payment Rate Update
Hospice Quality Reporting Requirements
Updates On Payment Reform
FY2014 Hospice Wage Index
Proposed Rule
2
Proposed FY2014 Hospice Payment Update Percentage
Hospital Marketbasket

Productivity adjustment reduction
Hospice-specific marketbasket
reduction
FY2014 Hospice Payment Update %


Updated wage index
Estimated Final FY2014 Hospice Payment
Update %
2.5%
-0.4%
-0.3%
1.8%
- 0.7%
1.1%
Wage Index Tables

FY2014 wage index tables
 http://www.cms.gov/Medicare/Medicare-Fee-for-
Service-Payment/Hospice/index.html


NHPCO will issue wage index calculator and stateby-state charts in coming days
Watch NHPCO website at
www.nhpco.org/regulatory
Rate Comparisons
4
Level of Care
FY2013
National Rate
FY2014
National
Rate
Routine Home
Care
$153.45
$156.21
FY2014
National Rate
with
Sequestration
$153.08
Continuous Home
Care
Inpatient Respite
$895.56
$911.68
$893.45
$158.72
$682.59
$161.58
$694.88
$158.35
$680.98
General
Inpatient Care
Big Changes Coming
5
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
Coding requirements – NO debility or adult failure
to thrive
Implementation of HIS – Hospice Item Set for all
patients
Implementation of Hospice Experience of Care
survey (Hospice CAHPS)
Payment Reform
Cost report changes
Questions and Comments
7
Multiple Diagnoses on Claim Form
Debility, Adult Failure to Thrive
Alzheimer’s and Other Dementias
Using ICD-9-CM Coding Conventions
Clarifications on Coding Requirements
8
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“All of a patient’s coexisting or additional
diagnoses” related to the terminal illness or related
conditions should be reported on the hospice claims
72% of hospice claims report only one diagnosis
CMS conclusions.....
Debility and Adult Failure to Thrive
9
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Diagnoses found in “Symptoms, Signs, and IllDefined Conditions” section of ICD-9-CM
“Debility” and “adult failure to thrive” SHOULD
NOT be used as principal hospice diagnoses on the
hospice claim form
Reference – ICD-9-CM Coding Manual
Choose the diagnosis “most contributory” to the
terminal illness
Claims with this diagnosis will not be paid and
will be returned to provider (RTP)
Alzheimer’s and Other Dementias
10

Diagnoses in coding classification “Mental,
Behavioral, and Neurodevelopmental Disorders”
 Not
allowable as a principal diagnosis per ICD-9-CM
coding guidelines

Diagnoses in ICD-9-CM coding classification
“Diseases of the Nervous System and Sense
Organs”
 Can
be used as principal diagnoses per ICD-9-CM
coding guidelines
Final Message on Coding Conventions
11


Imperative that hospice providers follow ICD-9-CM
coding guidelines and sequencing rules for all
diagnoses
Pay particular attention to dementia coding
 Dementia
codes found in more than one ICD-9-CM
coding chapter

Code the most definitive, contributory terminal
illness in the principal diagnosis field
 with
all other related conditions in the additional
diagnoses fields for hospice claims reporting
Questions and Comments
13
Quality Reporting
Quality Reporting
14

2013/2014 Data Collection and Submission
 QAPI
structural measure
 NQF #0209 – pain measures


CMS proposes that these measures discontinued
after FY2014 data collection year OR
CMS proposes to continue using #0209 until
another pain outcome measure is available
New Quality Reporting
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
Hospice Item Set (HIS)
 Proposed
to implement July 1, 2014
 Data on admission and discharge of every patient
 Data collection to include information for 7 new quality
measures
 Hospices who fail to report quality data via the HIS
system in 2014 will have a 2% marketbasket reduction
for FY2016

Public reporting on hospice quality measures
 Not
initiated prior to 2017
Seven New Quality Measures
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NQF Measure #
Hospice Quality Measure Description
NQF #1617
Patients Treated with an Opioid who are Given
a Bowel Regimen
NQF #1634
Pain Screening
NQF #1637
Pain Assessment
NQF #1638
Dyspnea Treatment
NQF #1639
Dyspnea Screening
NQF #1641
Treatment Preferences
NQF #1647
Beliefs/Values Addressed (if desired by the
patient)
HIS Forms Now Available
17
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http://www.cms.gov/Regulations-andGuidance/Legislation/PaperworkReductionActof19
95/PRA-ListingItems/CMS1252151.html?DLPage=1&DLSort=1&D
LSortDir=descending
HIS Publishes HIS Forms
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One form for each admission
Administrative information
 Measure support information

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Preferences
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Health conditions
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NQF #1641 – Treatment preferences
NQF #1647 – Beliefs/Values Addressed (if desired by the patient)
NQF #1634 Pain Screening
NQF #1637 Pain Assessment
NQF #1638 Dyspnea Treatment
NQF #1639 Dyspnea Screening
Medications

NQF #1617 - Patients treated with an opioid who are given a
bowel regimen
HIS Publishes HIS Forms
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
One form for each discharge
 Demographic
data
 Reason for discharge
New Quality Reporting
20
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Hospice Experience of Care Survey
 Post-death
caregiver survey
 Hospices required to contract with a vendor for
survey administration and quarterly data
submission
 Proposed start date: CY2015
 First quarter – “dry run” for at least 1 month
 Mandatory compliance – April 1, 2015
 Fewer than 50 deaths in year: exempt
CMS Website Location
21
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http://www.cms.gov/Regulations-andGuidance/Legislation/PaperworkReductionActof19
95/PRA-Listing-Items/CMS10475.html?DLPage=1&DLFilter=hospice&DLSort=
1&DLSortDir=descending
Three Experience of Care Surveys
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o
o
Home
Nursing Home
Inpatient
Set of core questions with additional setting specific
questions
Location at death determines which version is used
Reconsideration process
for hospice quality reporting


A process will be created to allow hospices that
have been notified of non-compliance with hospice
quality reporting requirements
May request reconsideration of FY 2014 payment
determinations
Questions and Comments
Hospice Payment Reform
Payment Reform Options

U-shaped model of resource use
 Considering
a tiered approach with payment tiers
based on length of stay
Short-stay add-on payment
 Case-mix adjustment
 Rebase ( ) the routine home care rate
 Site of service adjustment for hospice patients
in nursing facilities

U-shaped Model
27
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Higher payments at the beginning of care
Higher payments in the last days of life
Lower payments in the “middle” of care
No determination on number of days or payment
level
Short stay add-on
28
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
Could improve payment accuracy
Somewhat like home health Low Utilization
Payment Amount (LUPA)
Case mix adjustment
29
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Could be considered when more diagnosis data is
available
Contingent on data gathering from multiple
diagnoses on claim form
Rebase the Routine Home Care Rate
Routine Home
1983 Cost per
Inflation Factor
Care Components
Day
FY2011 Cost
per Day
Example of
rates for
FY2014
Nursing Care
Home Health Aide
Social
Services/Therapy
$16.25
$12.74
$3.23
N/A
N/A
N/A
$56.54
$19.24
$10.29
$60.83
$20.70
$11.07
Home respite
Interdisciplinary
group
$1.46
$2.78
X 3.1704
X 3.1704
$4.63
$8.81
$4.98
$9.48
Drugs
Supplies
Equipment
Outpatient
Hospital Therapies
$2.78
$4.49
$1.13
$2.99
X 3.1704
X 3.1704
X 3.1704
X 3.1704
$3.74
$14.23
$3.58
$9.48
$4.02
$15.31
$3.85
$10.20
TOTAL
$46.25
$130.54
$140.44
Note: No action proposed on this issue this year.
Proposed
FY2014
Rates
$156.21
CMS Commentary on Rebasing
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Do not have the data to support rebasing six of the nine
cost components described in the 1983 final rule
Drugs, supplies, and equipment costs -- not available from
hospice claims data
Cost report data not sufficiently detailed
Could consider rebasing:
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Nursing
Home health aide
Social services/therapy
Comprise 69.7% of RHC rate
Use FY2011 cost report data matched to FY2011 claims
data
Site of service rate adjustment for
nursing home patients on hospice

Issues
 Growth
 OIG
Report in 2011 – 263 hospices have 66% or more
patients in nursing homes
 Possible
efficiencies – multiple patients in one nursing
home, < drive time and < mileage
 Higher aide visits and time for hospice patients in
nursing homes

NO action proposed on this issue this year
Additional Data Collection

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January 2013, CMS received comments regarding
additional data collection
Considering input
Additional data to be issued as a change request
(CR) this spring or summer
Interested Policymakers

MedPAC – U-shaped curve and modeling
 June

2013 Report to Congress
CMS
 Abt
Associates and Technical Expert Panel
 Extensive analysis of claims and cost report data

HHS Assistant Secretary for Planning and Evaluation
 ASPE
 Extensive
length
data analysis – especially visits and visit
VALUE BASED PURCHASING
35

Value based purchasing – pilot testing

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Utilize already implemented measures
Implement pilot by January 1, 2016
Questions and Comments
Want to send comments?


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Go to www.regulations.gov
In the search box, type hospice
The proposed rule, CMS-1449-P, will come up.
Click the blue “Comment Now” box to submit your
comments.
An official letter from your hospice may be
attached.
Address

Address the letter as follows:
Marilyn Tavenner, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–1449–P
P.O. Box 8010
Baltimore, MD 21244–8010

Comments are due June 28, 2013
Thank you for your time and input!