by Kristin Rowan, Editor
2025 Hospice Final Rule Update
On July 30, 2024, CMS issued its final rule for the 2025 Hospice Final Rule Update (CMS-1810-F), with updates to HQRP and HOPE. The rule also finalizes a proposal to change the statistical area delineations. This will impact the hospice wage index. The rule includes clarifications on the hospice election statement and notice of election as well as clarifying language around hospice admission and certification of terminal illness.
Wage Decrease for Some Hospices Assigned to a New Area
The change in area delineations will have a negative impact on some hospices. They will see a decrease in payments based on their new area. However, CMS emphasizes that, regardless of the area change, the maximum change is a 5% decrease from the 2024 wage index, as there is a 5% cap on any decrease to the wage index.
2025 Hospice Final Rule Routine Annual Rate Setting Changes
Just one month after proposing additional deduction to the home health payment rate, the 2025 hospice final rule increases the base rate by 2.9%. This is an aggregate of a 3.4% inpatient hospital increase and a 0.5% productivity decrease. The quality data reporting requirement remains. Hospices that do not submit quality data would still see a 4% decrease in payment rates, yielding an aggregate 1.1% decrease. The payment update also includes an aggregate cap of $34,465.34 per individual per year.
Hospice Quality Reporting Program (HQRP)
The new rule includes two new process measures to HQRP:
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- Timely Follow-up for Pain Impact
- Timely Follow-up for Non-Pain Symptom Impact
These two measures are expected to begin in 2028 and address hopsice care delivery documentation on whether a follow-up visit occurred with 48 hours of the first assessment. The measures include visits where there was an impact of moderate to severe symptoms, both with and without pain.
Adoption and Implementation of HOPE
Hospice Outcomes and Patient Evaluation (HOPE) will replace the current Hospice Item Set (HIS) structure. The gradual roll-out will begin in FY 2025 and will collect data at different time points throughout a hospice stay. In contrast, HIS only collected data at admission and discharge.
New or expanded categories of HOPE relative to HIS include:
Changes to CAHPS Survey
CMS conducted an experiment in 2021 surrounding the Hospice CAHPS Survey. Based on those results, the final rule will implement these change to the survey:
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- The addition of a web-mail mode (email invitation to a web survey, with mail follow-up to non-responders).
- A shortened and simplified survey.
- Modifications to survey administration protocols to include a pre-notification letter and extension of the field period from 42 to 49 days.
- The addition of a new, two-item Care Preferences measure.
- Revisions to the existing Hospice Team Communication measure and the existing Getting Hospice Care Training measure.
- The removal of three nursing home items and additional survey items impacted by other proposed changes in this rule.
Hospice Special Focus Program (SFP)
The SFP allows CMS to monitor those hospices that are identified as poor performers based on quality indicators from the CAHPS surveys. Additional oversight from CMS will “enable continuous improvement” for those hospices identified. The four measures used to determine poor performance are Help for Pain and Symptoms, Getting Timely Help, Willingness to Recommend this Hospice, and Overall Rating of this Hospice.
According to CMS, the final rule includes changes to the Overall Rating of this Hospice measure. CMS states that these changes are not substantive and will not impact the SFP algorithm. “CMS adjusts measure scores for mode of survey administrations, so the introduction of a new mode should not impact measure scores.”
NAHC previously submitted comments to CMS stating that some aspects of the Hospice Special Focus Program are flawed and need to be adjusted for accuracy and fairness. NAHC/NHPCO has created a research project to understand the impact and validity of the Hospice Special Focus Program.
2025 Hospice Final Rule Conditions of Participation and Payment Requirements
There are language discrepancies in existing hospice requirements for medical director and physician designee, physician member, and payment requirements for the certification of the terminal illness and admission to hospice care. Therefore, CMS is making technical changes to the CoPs by adding the physician mmever of the hospice IDG as someone who can review technical information and provide certification of life expectancy.
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Kristin Rowan has been working at Healthcare at Home: The Rowan Report since 2008. She has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in event planning, sales, and marketing strategy. She has recently taken on the role of Editor of The Rowan Report and will add her voice to current Home Care topics as well as marketing tips for home care agencies. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com
©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com
