Hospice Hope

Admin

by Rowan Report | Jul 10, 2025 | Admin, CMS, Hospice, Outcomes, Regulatory

by Peggy Rattarree, Principle Product Manager, Curantis Solutions

Hospice HOPE

The importance of documenting symptom impact for patient-centered care

In hospice care, the focus isn’t just on treating symptoms; it’s on improving the quality of life for patients and their families. This is where Hospice HOPE takes center stage, emphasizing the importance of documenting symptom impact to deliver truly patient-centered care. By understanding how symptoms affect each patient’s physical, emotional, and psychosocial well-being, hospice teams can provide care that aligns with their unique needs and goals.

What is hospice HOPE?

Hospice HOPE stands for Hospice Outcomes and Patient Evaluation. It’s a philosophy that places the patient’s comfort, dignity, and goals at the forefront of care delivery. Documenting symptom impact is a critical part of this approach because it provides a detailed understanding of how symptoms affect the patient’s overall quality of life.

In hospice care, every patient’s journey is unique. By actively tracking and documenting symptom impact, care providers can move beyond generic treatments and embrace a truly individualized approach that prioritizes what matters most to the patient.

Why documenting symptom impact matters?

Moves us to patient-centered care

Documenting symptom impact allows hospice teams to focus on what truly matters to the patient. Instead of simply addressing symptoms like pain, nausea, or fatigue in isolation, it provides a holistic view of how these symptoms affect the patient’s daily life. For example:

Pain
- How does it limit mobility or the ability to participate in meaningful activities?
Fatigue
- Is it preventing patients from spending time with loved ones?
Nausea
- Is it reducing their ability to eat or enjoy meals?

By asking these questions and recording the answers, hospice providers can better tailor interventions to manage not just symptom management but the overall patient experience.

Improves communication across the care team

In hospice care, communication is everything. Documenting symptom impact ensures that every member of the interdisciplinary team (IDT), from nurses and physicians to social workers and chaplains, has access to the same comprehensive information.

This documentation:

Creates a shared understanding of the patient’s condition
Helps align the team’s goals with the patient’s priorities
Reduces duplication of efforts and enhances care coordination

When everyone is on the same page, patients and families receive more seamless, cohesive care.

Supports compliance and quality standards

Regulatory bodies like CMS (Centers for Medicare & Medicaid Services) require hospices to document and monitor patient symptoms to ensure care quality. But beyond compliance, tracking symptom impact demonstrates a commitment to continuous improvement.

Documenting symptom impact allows hospices to:

Identify trends and gaps in care
Measure the effectiveness of interventions
Use data to advocate for better resources or innovations in care delivery

Empowers families and caregivers

When symptom impact is documented, families and caregivers gain a clearer understanding of their loved one’s condition. This transparency fosters trust and collaboration between the hospice team and the family, ensuring everyone is working toward the same goals.

For example, a caregiver might better understand why a loved one sleeps more during the day or avoids certain foods. These insights can help families feel more prepared and supported during a challenging time.

Final Thoughts

With CMS rolling out Hospice HOPE, documenting symptom impact is no longer optional. It’s the standard for compassionate, high-quality care. This shift helps hospice organizations go beyond symptom control and into whole-person care that honors each patient’s life journey.

This is part one in a two-part series on Hospice HOPE. Check back next week for part two.

# # #

Peggy Rattarree Curantis Solutions Hospice HOPE

Peggy is an IT professional with over 30 years’ experience. She has defined and developed software products in industries such as grocery management, financial services, and reporting and analytics. In her 2.5 years with Curantis, Peggy has helped to shape the definition and delivery of the application. She brings a passion for agility and has been integral in transitioning Curantis to an environment of delivery on cadence, release on demand.

Peggy has a Bachelor of Music degree from University of North Texas.

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in the Curantis Solutions blog and is reprinted here with permission. For more information or to request permission to print, please contact Curantis Solutions.

Workplace Violence in Home Health

Caregiver Safety

by Kristin Rowan | Jun 20, 2025 | Caregiver Safety, Caring for the Caregiver, Clinical, Home Health, Hospice

by Kristin Rowan, Editor

Workplace Violence and Policy Impact

Study of home health workers

A group of researchers from the University of Cincinnati, Ohio published a recent study¹ on the frequency and reporting procedures of workplace violence (WPV) in home healthcare. The study specifically addressed WPV in home healthcare, stating limited understanding of WPV in the home care setting. Most existing studies on WPV were hospital-based.

Frequency of Workplace Violence

Of the home health care workers (HHCW) surveyed, almost 37% responded that they experience both verbal and emotional violence in the workplace daily. More than 80% reported experiencing verbal aggression at some point. Physical violence is less prominent. 20% of respondants said they experience physical violence monthly. However, 56.6% said they have experienced physical violence at some point in their current agency. 76.6% of the time, the perpetrators of the violence are the patients of the HHCW.

Fig. 1 Frequency of occurrence of physical, verbal, emotional, and sexual abuse as a function of time: daily, weekly, monthly, <yearly, yearly, and never.

Reporting Workplace Violence

All of the study participants indicated they had knowledge of workplace violence reporting procedures in their agencies, but 26.7% were unsure if the policies are contained in the employee handbook. 46.7% were uncertain as to whether the agency offered WPV or de-escalation training and 66% said prevention and de-escalation training was not mandatory. Unfortunately, 40% said their management did not encourage reporting and 33% said they were not comfortable approaching management about WPV. Despite the frequency of WPV among the respondents, none of the participants reported these incidents to management.

Thoughts

According to this, and other research studies on workplace violence in home healthcare, the problem is prevalent and persistent. Most HHCWs have experienced some sort of aggression, violence, or abuse in the course of performing their jobs. Of those who have, most do not report the incidents to management. Most HHCWs have not been trained in prevention or de-escalation. Even with training, HHCWs need a way to get immediate help. Unfortunately, most do not have an emergency alert system on their person during home visits.

Solution

Care at Home agencies, including non-medical supportive care, home health, hospice, and any other lone workers who are visiting patients in their homes, need safety policies and procedures. Agencies must include the same in the employee handbook, explain during orientation, and make available to HHCWs digitally.

Policies and procedures should include:

A safety committee comprised of management, back office staff, and field workers
A clearly written policy regarding physical, emotional, verbal, and sexual abuse
- Against a patient or their family/friends by a HHCW
- Against a HHCW by a patient or their family/friends
- Against a HHCW by a colleague or manager
- Against a HHCW by the environment in which they work (i.e. aggressive pets, weapons, cigarette smoking indoors, etc.)
A digital reporting system that employees can use without having to approach management individually
A clearly written policy on the management response to violence reporting
A clearly written policy forbidding any retaliation or discrimination against a reporting employee
Required research about new patients including
- Background/History of violence and/or mental instability
- Neighborhood safety rating
- Family members likely to be in the home and their history of violence and/or mental instability

Additional Tools for HHCWs

Workplace violence against HHCWs is not “if,” but “when.” It is the responsibility of the agencies to lower the risk, lower the percentage of “whens,” and encourage reporting. If you’re not sure how to begin, hire a consultant to help you build your safety committee and write your policies. It doesn’t matter how you start implementing safety protocols, as long as you follow through and protect your employees.

# # #

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

1. Obariase, E.; Bellacov, R.; Gillespie, G.; Davis, K. (2025). Assessing Workplace Violence and Policy Impact: A Cross-sectional Study of Home Healthcare Workers. Home Healthcare Now, 43(3), 150-156. doi: 10.1097/NHH.0000000000001345

The Alliance Responds

Advocacy

by Kristin Rowan | Jun 13, 2025 | Advocacy, CMS, Hospice

by Kristin Rowan, Editor

The Alliance Responds to CMS Hospice Update

The Alliance responds to CMS-1835-P, the FY 2026 Hospice Wage Index, Conditions of Participation, and Quality Reporting Program Requirements updates. On June 10, 2025, in a 25 page letter to Dr. Mehemet Oz, CEO for The National Alliance for Care at Home Steve Landers, MD, MPH lays out the constraints and financial burdens hospice agencies will face if these updates are enacted.

Payment Rate Update

Increase Less than Inflation

In the rule for FY 2026, CMS proposes a 3.2 percent market basket increase and a .8 percent productivity decrease, yielding a 2.4 percent increase overall. According to the letter, inflation has raised medical care prices by 3.1 percent, leaving a shortfall of .7 percent. Hospices are also plagued by the same workforce shortage the rest of the medical industry faces. Workforce shortages result in fewer qualified people than there are available positions, which drives wages up. BLS data indicates the wage increase for 2025 was 4.4%. The Alliance argues that the 2.4% net increase falls well short of the actual expense increase.

Faulty Data

In a recent article, we outlined the process that CMS uses to determine the market basket update. The Alliance echos our information, showing the market basket forecast is well below actual increases. The Alliance further argues that the shortfall compounds, leaving the base rate increasingly smaller with each forecast. The current estimate is a 4.9% pay rate gap. CMS contends there is no way to adjust for forecast errors. The Alliance has a simple solution: manually adjust the payment rate every year when the finalized number are above the forecasted numbers BEFORE adding the next year’s payment rate increase.

Likewise, The Alliance concurs with The Rowan Report sentiment that productivity cannot increase in hospice like it does in less labor-intensive sectors. Landers also mentions the failure to consider travel costs, the wage differences in rural areas, and the lack of reclassification options in hospice care.

Payment Rate Recommendations

As any well-drafted response should, The Alliance provides actionable recommendations in each section. For payment rate updates, The Alliance recommends:

We recommend CMS examine closely more recent data and increase final payment rates for FY 2026.
We urge CMS to explore all available avenues to address the forecast error shortfall, such as through a one-time adjustment.
We encourage CMS to collaborate with stakeholders to address the shortcomings of relying upon hospital data to determine hospice payment rates, and ways to achieve parity across provider types with respect to geographic area wage adjustments.

HIS to HOPE Transition

Also addressed in the letter is opposition to the timeline of the HIS to HOPE transition. The Alliance restates much of what was in the joint letter to CMS urging the delay of the HOPE tool adoption. That letter was a joint venture between The National Alliance for Care at Home (The Alliance), LeadingAge, and the National Partnership for Healthcare and Hospice Innovation (NPHI).

The consequence of adverse outcomes cannot be understated. The risk of negative financial consequences for hospice providers is
largely dependent this year on the success of two transitions—iQIES and HOPE— neither of which are within their control.

Steve Landers, MD, MPH

CEO, National Alliance for Care at Home

HOPE Transition Recommendations

Considering the volatility inherent in a reporting transition of this magnitude and the lack of clear information provided to date, we respectfully request CMS waive the HOPE timeliness submission requirement for two calendar quarters post implementation.
We further respectfully request that CMS delay the HOPE implementation date until at least six months after CMS education and training, beyond that which is introductory and that is scheduled for spring/summer 2025, the final validation utility tool specifications are available and the application for iQIES access has been opened for hospices.

Digital and Future Hospice Measurements

Among the digital hospice measurements is an interoperability measurement. The Alliance supports interoperability and data exchange across medical care entities, but stresses to CMS that many hospices do not have digital EHR systems, cannot afford to maintain such systems, and have not received the federal financial support necessary to meet this objective.

The Alliance also objects, not in theory, but in practical application, to the nutrition measure noted in future hospice measures. Nutrition for a hospice patient is vastly different than for other patients and should be implemented as a process measure, rather than having specific goals for food intake and nutrition.

Similarly, the well-being measure is not designed for hospice care. In other sectors of healthcare, well-being incorporates measures for mental, social and physical health and focuses on curative plans. Hospice care focuses on person-centered care, emphasizing the desires of the patient as they are balanced against religious, cultural, and personal beliefs. The well-being measure must be curated to fit hospice care.

The Alliance - Conclusion

The Alliance values CMS’s ongoing commitment to enhancing hospice care quality,
ensuring program integrity, and improving patient outcomes. We appreciate your
consideration of our comments and look forward to ongoing dialogue to achieve these
shared objectives.

The Rowan Report - Conclusion

The Alliance has, as always, done an exemplary job at explaining the industry position on the CMS rule. Likewise, it has outlined each step CMS should take to view the updates through a hospice lens rather than a hospital lens. We commend and support The Alliance statement and position. As this is an ongoing topic until the final rule is implemented, we will continue to provide updates as they become available.

If you are a member of The Alliance, you can read the full 25 page letter here.

# # #

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Painting Pictures

Admin

by Elizabeth E. Hogue, Esq. | Jun 13, 2025 | Admin, Clinical, Home Health, Hospice

by Elizabeth E. Hogue, Esq.

"Painting Pictures" of Patients

Painting Pictures in clinical documentation to achieve positive audit results. As the fight against “fraud, abuse and waste” continues, responding to audits has become an ongoing burden for many providers. Providers have repeatedly been urged to “paint a picture” of patients in clinical documentation in order to help achieve positive results. “Painting a picture” of the patient, however, may have become more difficult as the use of electronic health records (EHRs) has increased. That is, it’s difficult to adequately describe patients’ conditions when there are so many boxes to check and blanks to fill in.

Copy, Paste, Repeat

When it comes to narrative descriptions of patients’ conditions, it is extremely tempting to “copy and paste,” “cut and paste” and/or “copy forward” previous documentation in the EHR. The copy and paste feature allows users to use the content of another entry and to select information from an original or previous source to reproduce in another location. The copy forward capability replicates all or some information from a previous note to a current note, while the cut and paste feature removes documentation from the original location and places it in another location. In addition to the obvious potential problems for quality of care related to the use of these functions, auditors are understandably skeptical of documentation that repeats itself throughout patients’ medical records.

Painting Pictures of Fraud

Auditors are especially likely to deny claims that include documentation that was obviously copied using the above functions, when the information copied “sticks out like a sore thumb.” If hospice staff document, for example, that “the patient eats a lot of Mexican food” over and over in clinicians’ visit notes, auditors are understandably skeptical about whether services were necessary for a hospice patient who seems to have a continuous robust appetite or whether services were, in fact, rendered.

How to Paint the Picture

What does it mean to “paint a picture?” If a home health patient needs wound care or injections of medications, for example, the “picture” must account for why patients or their caregivers are not performing these activities themselves. Clinicians need to describe the following in a “picture” of the patient:

Does the patient live alone or have caregivers?
Why can’t patients do wound care or self-inject medications
Why can’t caregivers perform these activities?
What attempts did clinicians make to assist patients and caregivers to provide wound care and injections?
Why were these attempts unsuccessful?
What attempts were made to find other caregivers – either paid or voluntary – who might provide these types of care?
What were the results of these attempts to find other caregivers?
Despite the initial inability of patients and caregivers to render this care themselves, what efforts did clinicians make to help ensure that they became able to do so?

Get the Picture?

It’s difficult, if not impossible, to paint the above picture using only the boxes and blanks of forms in EHRs. More is needed if providers are serious about positive audit results.

# # #

Elizabeth Hogue is an attorney in private practice with extensive experience in health care. She represents clients across the U.S., including professional associations, managed care providers, hospitals, long-term care facilities, home health agencies, durable medical equipment companies, and hospices.

No portion of this material may be reproduced in any form without the advance written permission of the author.

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

AI in Home Care

Artificial Intelligence

by Rowan Report | Jun 13, 2025 | Artificial Intelligence, Home Health, Hospice

by Laurie Orlov, Founder, Aging and Health Technology Watch

The Future of AI in Home Care

New Research Report

Wed, 06/04/2025

PORT SAINT LUCIE, FL, UNITED STATES, June 4, 2025 /EINPresswire.com/ — The home care industry is facing a crisis. Driven by demographic shifts, longer life expectancy, and rising rates of chronic illness and cognitive decline, the demand for in-home personal care and home health care is surging. This will accelerate as the baby boomers age into their later years – in January, the oldest of the 76 million baby boomers will turn 80. At the same time, the care industries will face a critical shortage of all categories of care delivery, with millions of additional workers needed over the next decade. Against this backdrop, AI technology has emerged to help older adults in multiple ways. In a 2023 report, The Future of AI and Older Adults, AI was already able to produce insights about a person’s health needs and offer a chatbot to help with post-hospital care. In a subsequent 2023 report, AI and the Future of Care Work, it was apparent that AI could help generate an appropriate care plan and that an ‘AI Caregiver’ role was emerging to supplement in-person care delivery. In the 2024 report, The Future of AI in Senior Living and Care, AI was being used to analyze hospital discharge information to compare patient needs to nursing home capacity.

Today there are many more initiatives and new possibilities for addressing multiple aspects of both private duty home care and home health operations, including assistance with recruiting and onboarding workers, using data to create and update care-related documents, and introducing AI agents that can be assigned to complete specific tasks. As current industry leaders note, AI tech is playing a role in care oversight and enabling the creating of hybrid models – an increasingly likely combination of in-person care supplemented with AI.

This report draws insights from experts across home care, home health care, plus software and device providers, and healthcare sectors to examine how AI is currently being used and suggest what lies ahead within the next five years.

The report can be found at this link: https://www.ageinplacetech.com/page/future-ai-home-care

# # #

Laurie Orlov The Future of AI in Home Care

Laurie M. Orlov, a tech industry veteran, writer, speaker, elder care advocate, is the founder of Aging and Health Technology Watch — market research, trends, blogs and reports that provide thought leadership, analysis and guidance about health and aging-related technologies and services that enable boomers and seniors to sustain and improve their quality of life. In her previous career, Laurie spent many years in the technology industry, including 9 years at analyst firm Forrester Research. She has spoken regularly and delivered keynote speeches at forums, industry consortia, conferences, and symposia, most recently on the business of technology for boomers and seniors. She advises large organizations as well as non-profits and entrepreneurs about trends and opportunities in the age-related technology market. Her perspectives have been quoted in the Wall Street Journal, the New York Times, Vox, Senior Housing News, CNN Health, AARP Bulletin and Consumer Reports. She has a graduate certification in Geriatric Care Management from the University of Florida and a BA in Music from the University of Rochester. Laurie has provided testimony about technology at a Senate Aging Committee hearing and has consulted to AARP. Advisory clients have included AARP, AOL, Argentum, Bose, Calix, CDW, Microsoft, Novartis, and Philips. Her reports include: The Market Overview Technology for Aging 2025, The Future of AI in Senior Living and Care, The User Experience Needs An Upgrade 2024, The Future of AI and Older and Older Adults 2023, The Future of Care Work and Older Adults 2023, The Future of Sensors and Older Adults 2022, Beyond DIY: The Future of Smart Homes and Older Adults 2021, and The Future of Wearables and Older Adults 2021. Laurie has been named one of the Women Leaders in Voice, Top 50 Influencers in Aging by Next Avenue and one of the Women leading global innovation on AgeTech.

©2025 by Aging and Health Technology Watch. All rights reserved. This introduction and link are printed with permission from the author. For more information or to request usage rights, please contact Laurie Orlov.

BREAKING NEWS: Intrepid USA Files Bankruptcy

Breaking News

by Kristin Rowan | Jun 6, 2025 | Breaking News, Home Health, Hospice, Legal, M&A, Medicaid, Medicare

by Kristin Rowan, Editor

*Editor’s note: This article has been updated to remove inaccurate information from the Intrepid USA website.

Intrepid USA Files Bankruptcy

Intrepid USA, once among the largest providers of home health and hospice services, files bankruptcy in Texas. With more than $90 million in revenue in 2023, Intrepid operated more than 60 home health and hospice locations in 17 states. The Chapter 7 filing leaves no road to recovery. Chapter 7 allows the company to liquidate assets and distribute the proceeds. According to the Texas Southern Bankruptcy Court, Intrepid USA filed a voluntary petition for Chapter 7 bankruptcy on May 29, 2025.

Troubled History Plagues Company

Intrepid USA has a troubled past that it seems may have caught up with them. The U.S. Department of Justice (DoJ) alleges that between 2016 and 2021, Intrepid home healthcare agencies engaged in fraud. In violation of the False Claims Act, Intrepid filed Medicare claims for patients who did not qualify for home health, services that were not medically necessary, services provided by untrained staff, and services that were never provided. In August, 2024, Intrepid agreed to pay $3.85 million to resolve the allegations. The allegations were brought to the DoJ by two former employees of Intrepid under whistleblower provisions.

This is not the first DoJ lawsuit against Intrepid USA. In 2006, when Intrepid owned 150 agencies across the country, the company entered into an $8 million settlement agreement to resolve similar allegations. The DoJ alleged that from 1997 to 2004 Intrepid violated the False Claims Act by billing Medicare and TRICARE for services not provided by a qualified person, failing to maintain complete documentation for its claims, and other violations of Medicare regulations. Additionally, the DoJ alleged that Intrepid, in 2002 and 2003, fraudulently billed Medicaid for home care services provided to patients who were hospitalized at the time of the supposed care.

Private Equity Backing

Sometime around Q3 of 2006, Intrepid USA received financial backing from Patriarch Partners, led by Lynn Tilton. In August of 2020, Patriarch filed a notice of removal with the Supreme Court of New York. In 2021, Intrepid announced it was gearing up for rapid growth fueled by new private equity investors. Then CEO John Kunysz indicated the infusion of capital would fund opportunities for growth through acquisition.

Divest, not Acquire

Despite the influx of capital and the plan to grow through acquisition, by 2024, Intrepid was selling its assets. In August of 2024, Humana acquired 30 Intrepid branch locations and rebranded them under the CenterWell Home Health brand. The sale was part of Patriarch Partners’s Zohar Funds bankruptcy case. In November of 2024, New Day Healthcare acquired Intrepid’s hospice locations in Missouri and Texas.

$0 Revenue; 0 Value

The bankruptcy filing shows that Intrepid USA had $90 million in revenue in 2023, $50 million in revenue in 2024, and $0 in revenue so far in 2025. Chapter 7 bankruptcy is usually supervised by the court, allowing the filing company to sell assets without having to use the revenue generated by the sale to pay off debts. Intrepid listed $1 to $10 million in assets and $88 million in debts at the time of the filing.

Who will take the loss?

The Intrepid USA website still lists 55 active home health and hospice locations in 11 states. However, 30 of those locations are now listed on the CenterWell website and at least 5 other locations were part of the sale to New Day Healthcare. It is unknown if Intrepid has any locations still in operation. The company did not respond to our request for a statement.

The website also has a list of partners and investors. The Rowan Report reached out to the partners with whom we are familiar for more information. We will provide updates from them once we reach them.

Final Thoughts

The recent divestiture of home health and hospice locations to New Day and CenterWell will hopefully minimize the number of patients who are losing their home health or hospice provider. Millions of dollars in future fraudulent claims will remain in the Medicare, TRICARE, and Medicaid coffers. Conversely, the partners and investors in Intrepid USA may face some loss. We will provide any important updates and comments from the impacted companies as available.

# # #

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Fraudsters Arrested, Oz Issues Warning

CMS

by Kristin Rowan | Jun 6, 2025 | CMS, Hospice, Medicaid, Medicare, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Fraudsters Arrested, Oz Issues Warning

Fraud in California

Fraudsters arrested in West Covina, CA this week were allegedly running a Medicare scheme. Authorities arrested hospice owner-operator Normita Sierra. They charged her with nine counts of health care fraud, one count of conspiracy, and four counts illegal remuneration (kick-backs) for health care referrals. The U.S. Attorney’s Office named co-conspirator Rowena Elegado. They also arrested her and charged her with one count of conspiracy and four counts of illegal remuneration for health care referrals.

Kickbacks

Sierra and Elegado worked together to pay marketers to recruit patients who did not have a hospice referral from their PCP and who were not terminally ill. Some of the kickbacks paid to marketers were as high as $1,300 per patient per month. After six months, the patients were referred out to Sierra’s home health company.

Medicare Claims

According to the U.S. Attorney’s Office, from 2018 to 2022, Sierra’s hospice agences submitted $4.8 million in fraudulent claims. Of those claims, Medicare paid approximately $3.8 million.

Dr. Oz Issues Warning

In a video statement, Dr. Oz explained how Medicare recipients are falling victim to scams. Sales people call, email, and even knock on your door, offering advice, free samples, and referrals. These marketers have one goal: get you sign a piece of paper. That paper signs you up for hospice care and agrees to allow a specific hospice agency to provide that care. The hospice agency then bills Medicare for services they never provide. Watch the video statement here.

HHS OIG Issues Consumer Alert

In a similar statement, HHS issued a consumer alert regarding DME companies. The alert warns that some DME companies are contacting Medicare beneficiaries. They claim to work for or on behalf of Medicare. Once they receive the patient’s Medicare number, they bill Medicare for unnecessary medical items. These items include urinary catheters, knee and back braces, orthotic braces, and prescription drugs, which may or may not ever be sent to the patient. HHS urges enrollees not to give their Medicare number to anyone. Further, they suggest regulary reviewing items charged to insurance, and refusing delivery of any medical supply not ordered by a physician.

Combating Waste, Fraud, and Abuse

Dr. Oz and CMS have spoken numerous times about combatting the waste, fraud, and abuse withing the Medicare and Medicaid systems. Originally a strong proponent for Medicare Advantage, Oz has promised to audit MA after discovering the government pays more for MA than traditional Medicare. Oz also promised to reduce the amount of prior authorization requests needed before a patient gets services. Oz responded to the Republican-backed House bill requiring more oversight on Medicaid eligibility. Oz indicated that some Medicaid patients are enrolled in more than one state and that Medicaid is paying for able-bodied patients. The waste, fraud and abuse across Medicare and Medicaid is costing the government between $1 and $10 billion and Dr. Oz plans to find it and make significant changes to the management of the system.

A Cautionary Tale for Hospice Providers

You may be thinking, “What does this have to do with me?” Unfortunately, even the most scrupulous hospice agencies can fall prey to marketers running schemes. There are legitimate referral resources in the market who can help your agency get more referrals and more clients. There are also underhanded marketers who know how the system works. These predators will promise new referrals (for a fee) and then enroll uneligible patients without your knowledge. If you are working with or looking for a referral partner for your hospice agency, use one that is referred by someone you trust, and/or do a lot of research on the company history before working with anyone. Be especially wary of the ones who promise much more than what most referral companies offer.

# # #

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Delay HOPE Tool

Advocacy

by Kristin Rowan | Jun 6, 2025 | Advocacy, CMS, Hospice, Regulatory

by Kristin Rowan, Editor

Advocacy Groups to CMS:

Delay HOPE Tool Implementation

“Delay HOPE Tool Implementation,” say multiple hospice advocacy groups. LeadingAge, the National Alliance for Care at Home (The Alliance), and the National Partnership for Healthcare and Hospice Innovation (NPHI) are urging CMS to delay the transition from HIS to HOPE. The three groups sent a joint letter to Dr. Mehmet Oz, CMS Administrator, earlier this week.

“Our associations remain fully committed to the [Hospice Quality Reporting Program (HQRP)], including the payment penalties for non-compliance, and recognize the critical importance of accurate, timely data submission to inform the delivery of high-quality hospice care. However, we have serious concerns about the potential for successful implementation of the HOPE tool.”

LeadingAge, The Alliance, NPHI

Hospice Advocacy

The concerns over agency readiness to implement the new tool center on the new reporting platform. Hospice agencies state they don’t have all the necessary information to develop a workable tool for submission. Therefore, the agencies have asked CMS to delay the implementation of the HOPE tool. They have called on CMS to wait until six months after agencies have access to education, training, and final validation specifications.

Hospice Rule Penalty

The hospice program through CMS requires substantial reporting for payment. Hospices that do not submit the required 90% of records, they receive an annual payment penalty of 4%. Combined with lower than sustainable payment increases, the 4% penalty results in a lower reimbursement rate over prior years. The associations worry that the lack of information and education will lead to lower reporting. In turn, the lower reporting lowers reimbursement rates. For hospices that are already struggling to survive, the penalty is devastating. The letter to CMS asked to waive the timeliness requirement for two quarters after implementation.

HOPE Tool Lacks Validation

CMS will have a Validation Utility Tool that agencies will need to use in order to ensure their software can successfully submit their data. CMS has not released the tool and indicates they may not until sometime in September. The HOPE tool is scheduled for implementation in October. There is not enough time between release of the validity tool and implementation of the HOPE tool for proper testing.

Hospice Agencies Lack Validation

In addition to validating data submission, hospice agencies have to enroll in the new submission portal, iQUIES. Enrollment requires a privacy security official and other staff. Additionally, it requires an application to access the system, background checks, and other actions. Thus far, hospice agencies do not have access to begin this process and there is no indication of how long it will take. The associations are concerned that the process may also involve significant financial cost to hospice agencies.

Resources

CMS released the Hospice Outcomes and Patient Evaluation (HOPE) Guidance Manual v1.01, a 138 page PDF, available here. The manual includes links to other resources for hospice agencies. Namely, a webpage with information on HOPE Data Submission Specifications has a “final” version of data specs available for download. Additionally, there are links to the Main Page here and technical information and updates here. The document urges vendors to register to get updates and important announcements.

Final Thoughts

There is no information yet as to a response to the letter from CMS. Thus far, CMS is still planning on keeping the October 1, 2025 HOPE implementation date. We will continue to report on updates from CMS and the advocacy groups.

# # #

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Update is Not an Increase

Hospice

by Kristin Rowan | May 1, 2025 | Hospice, Regulatory

by Kristin Rowan, Editor

Updates to Hospice Rule

On April 11, 2025, the Centers for Medicare and Medicaid Services (CMS) issued their proposed rule for hospice rates, Conditions of Participation (CoPs) and face-t0-face encounter requirements for FY 2026. The proposed rule also includes a change in regulatory text for the Hospice Quality Reporting Program.

Following Executive Order 14192, an attempt to reduce the expense attached to following Federal regulations, CMS is seeking feedback on streamlining regulations and reducing expenses. The RFI to submit responses can be found here.

Payment Updates

The proposed update to the hospice payment rate yields a net increase of 2.4 percent. This change includes a 3.2 percent market basket increase based on the estimate cost increase for inpatient hospitalization. The 0.8 percent productivity adjustment offsets the market basket increase. The quality data penalty of 4 percent remains in place.

Market Basket Objections

Not for the first time, commentors on CMS proposed rules objected to the use of the hospital wage index in determining hospice pay rates. According to a report from the Federal Register, a few commenters on the FY 2025 payment update opposed using the IPPS wage index to determine the hospice wage index. According to the commenters, the hospital wage index uses cost report wage data that excludes hospice wage costs. The exclusion of hospice costs skews the accuracy of wage adjustments for hospice providers.

In response to the same proposed rule, MedPAC recommended that wage index policies be repealed and replaced by new Medicare wage index systems that use all-employer, occupation-level wage data; account for wage differences across geographical areas, and match wages in adjacent local areas.

CMS Ignores Objections

Despite years of comments, objections, and suggestions to update the hospice wage index calculations using more accurate data, CMS continues to insist that using the pre-floor and pre-reclassified hospital wage index is the more appropriate for determining hospice payment rates. CMS states that this position is “longstanding and consistent with other Medicare payment systems.”

Productivity Adjustment

The productivity adjustment started with the Affordable Care Act. It’s stated purpose is to “reduce Medicare spending by recognizing that hospitals can improve their efficiency and productivity.” Average efficiency and productivity gains in all private non-farming businesses form the productivity adjustment.

The most recent document from CMS about the productivity adjustment comes from 2022, using data from 2019. The report shows that hospital growth falls far below the average growth of private non-farming businesses. Using two different methods of calculations, hospital growth falls between 0.2 and 0.3 percent. Non-farming business growth is 0.8 percent.

Labor Productivity

CMS uses labor productivity as its measure for the productivity adjustment for Medicare hospitals and hospices. The estimate for labor productivity across all private non-farming businesses is 2.0 percent. The calculation for hospital labor productivity is 0.8 percent. This is the number used in this year’s productivity adjustment. Actual labor productivity growth in hospitals from 1993 to 2018 was 0.4 percent.

Quality Reporting Reduction

Hospices that do not submit the required quality data incur a payment reduction of 4 percent. This yields a 1.6 percent decrease over last year’s rates after factoring in the 2.4 percent increase. Quality data reporting includes the HIS tool, administrative data, and CAHPS hospice survey. The threshold to avoid the 4 percent reduction includes submitting at least 90 percent of HIS records within 30 days of an event date and ongoing monthly participation in CAHPS surveys. The HOPE reporting tool replaces the HIS system beginning October 1, 2025. These requirements are not changing with the FY 2026 proposed rule, with the exception of the change from the HIS tool to the HOPE tool.

Comment from The Alliance

In last week’s newsletter, we summarized Dr. Steven Landers’s keynote address from the New England Home Care & Hospice Conference and Expo. Always passionate about care at home, and particularly about hospice, which he describes as “a national treasure,” Dr. Landers strongly stated that an “update is not an increase” when it doesn’t keep up with inflation and pay increases.

Final Thoughts

Every year, CMS, MedPAC, and HHS make changes to hospice and home health payment rates based on faulty information that doesn’t account for the nature of the work or the person-centered requirements of the industry. Non-farming industries can increase efficiency and productivity in myriad ways that cut staff. We see it in grocery stores with the increasing number of self-checkout lines. We see it in restaurants with QR code menus, ordering kiosks, and payment kiosks. There is no substitute for one-on-one contact in a home setting for care at home, particularly in hospice. Nurses can’t take on enough more patients in a day to make a meaningful impact on efficiency and productivity without sacrificing quality of care.

AI for Efficiency and Productivity

I’ve been speaking for some time now on the advantages of using augmented and generative intelligence in care at home. As long as CMS continues to lower reimbursement rates using the collective productivity rates of impertinent industries, care at home has to embrace the technology that increases productivity and efficiency in the office and in the field. Talk to text, documentation, scheduling, onboarding, and data analytics are readily available through AI platforms and drastically reduce costs across departments.

You can read about some of the AI tools here. For more information or to engage our consulting services for AI adoption, contact me directly.

# # #

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news, and speaker on Artificial Intelligence and Lone Worker Safety and state and national conferences.

She also runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

That’s a No-No

Admin

by Elizabeth E. Hogue, Esq. | Apr 24, 2025 | Admin, Hospice, Medicaid, Medicare, Medicare Advantage, Regulatory

by Elizabeth E. Hogue, Esq.

No-no # 1

“No-No” may seem like something you would say to a toddler, but there is a list of things agency owners do that they should not do. Many of these are things providers may not often consider. This article focuses on the use of private duty services by hospice and home health patients, and what hospices and home health agencies cannot do with regard to aide services.

Aide Services

Both home health and hospice services are usually intermittent and provided in patients’ homes. Patients and their families may elect to utilize the services of private duty/home care companies for additional assistance. At the same time, hospice and home health patients may receive aide services from hospices and home health agencies.

Conditions of Participation

According to Medicare Conditions of Participation (CoPs), hospice and home health aides can only provide personal care services, including bathing. Aides provided by private duty/home care companies may also provide personal care. Unlike aides provided by hospices and home health agencies, however, they can provide additional services; such as laundry, food preparation, light housekeeping, shopping, and running errands.

Private Duty Services

When patients use private duty services, they are often paying for these services out of their own pockets. Even if they have long-term care insurance, patients still bear the financial burden of paying for private duty services. Longterm care insurance often costs thousands of dollars that patients probably paid for themselves. Patients usually pay by the hour for these services.

That's a No-No

Patients may, of course, utilize private duty/home care services to perform any of the services described above. It seems, however, that hospices routinely tell patients who have private duty/home care that they will not provide aide services because private duty/home care aides are able to provide personal care for patients.

Breaking it Down

Here is an example: A hospice admitted a bedridden patient with urinary and fecal incontinence. The patient and caregiver requested aide services from the hospice five days a week to bathe him. He paid for a few hours of private duty/home care services each day. The hospice refused to provide aide services five days a week to bathe him because he had private duty/home care services. No-no!

Compelled to Provide Care

ospices must provide aide services consistent with patients’ needs related to their terminal illnesses. In the example above, the patient clearly had a need for aide services five days a week. If patients and their caregivers state that they prefer to use private caregivers for personal care, then hospices must document the refusal of hospice aide services offered, consistent with applicable standards of care. Then hospices are not required to provide aide services.

Profiteering

When hospices deny aide services that are consistent with applicable standards of care and require patients and caregivers to use private duty/home care services, hospices are shifting the cost of aide services onto patients and their families. Patients and their families may have to pay for additional private duty/home care services to meet patients’ needs. The result for hospices is that they do not incur the costs of aide services, thereby increasing their profits at the expense of patients and their families.

If hospice staff members who refuse to provide aide services to patients and require patients and their families to use private duty/home care services instead are compensated in any way based on the financial performance or profitability of the hospices, let’s hope they look good in orange jumpsuits!

Intent to Defraud

If the private duty/home care services are being paid for by any federal or state health care program; such as Medicaid, Medicaid waiver, VA, or TriCare; then both home health agencies and hospices have engaged in fraudulent conduct by shifting costs that they should have incurred onto other federal government programs.

God forbid that the hospice also owns the company from which patients receive private duty/home care services! Then hospices are limiting their costs while profiting from patients and their families.

Dig Deep and Find Your No-No's

Now is the time for all home health agencies and hospices especially to audit patients’ records to make certain that all patients have been offered services that they are required to provide. If patients and their families choose to use private duty/home care aides instead, documentation must show that they were offered the services but chose to use private duty/home care aides.

No-No's Final Thoughts

The bottom line is that hospices and home health agencies must always provide services needed by patients. Patients may choose to pay for services that are paid for by the Medicare hospice or home health benefits. Patients cannot be required to pay for services privately that hospices and home health agencies must provide. Unacceptable!

This article is the first in a series of “No-no” items for agency owners.

# # #

Elizabeth Hogue is an attorney in private practice with extensive experience in health care. She represents clients across the U.S., including professional associations, managed care providers, hospitals, long-term care facilities, home health agencies, durable medical equipment companies, and hospices.

No portion of this material may be reproduced in any form without the advance written permission of the author.

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

HIS to HOPE

Admin

by Rowan Report | Apr 11, 2025 | Admin, Hospice

by Vicki Goodman, CRO at Curantis Solutions

HIS to HOPE Transition in Hospice Care

What You Need to Know

As a hospice nurse, I am excited to share pivotal news that will significantly impact our field starting October 1st. In case you have been living under a rock, we are transitioning from the Hospice Item Set (HIS) to the Hospice Outcomes and Patient Evaluation (HOPE). This change is not just a modification in terminology; it represents a transformative shift towards a more patient-centered and holistic approach to hospice care. In this article, we will explore what this transition entails, its benefits, and how it will affect our daily practices.

Understanding the Transition from HIS to HOPE

The move from HIS to HOPE signifies an essential evolution in our approach to patient care. While HIS primarily focused on data collection and compliance with regulations, HOPE emphasizes measuring patient outcomes, quality of care, and overall patient experience. This transition encourages us to engage more deeply with our patients and their families, ensuring that their unique needs and preferences are at the forefront of the care we provide.

What is HOPE?

HOPE stands for Hospice Outcomes and Patient Evaluation. This new framework highlights several core principles:

Patient-Centered Care
- Focusing on individual patien needs and preferences
Quality of Care Assessment
- Evaluation how well we meet those needs
Holistic Approach
- Considering emotional, spiritual, and psychological factors in addition to physical health

Benefits of HOPE in Hospice Care

The adoption of the HOPE framework offers numerous advantages for both patients and healthcare providers:

Improved Patient Engagement
- By prioritizing patient preferences, we can foster stronger relationships and enhance the overall care experience
Enhanced Quality of Care
- Focused outcomes assessment allows us to identify areas for improvement and implement best practices
Recognition of Care Quality
- HOPE enables us to demonstrate the effectiveness of our care, leading to greater recognition of our contributions in hospice settings

HIS to HOPE Key Differences

Understanding the distinctions between HIS and HOPE can help clarify the shift in our practices. Here are some key differences

HIS to HOPE Vicki Goodman Curantis Solutions

The Role of Hospice Nurses in the HOPE Framework

As hospice nurses, our role in implementing HOPE will require a significant mindset shift. Here’s how we can adapt our practice:

Engage With Patients and Families
- Actively involve them in care planning and decision-making
Assess Holistically
- Look beyond clinical data to include emotional and spiritual assessments
Collaborate with Interdisciplinary Teams
- Work closely with all caregivers to ensure a comprehensive approach to patient care

By integrating these principles into our daily practice, we can enhance patient experiences and outcomes, ultimately providing the compassionate care that is the hallmark of hospice services.

Acknowledging Our Impact

As we transition to the HOPE framework, it’s essential to take a moment to give ourselves credit for the incredible work we already do. For most of us, patient-centered care has been at the heart of our practice long before HOPE was introduced. This new framework serves as validation, providing a structured approach to highlight the compassionate, individualized care we consistently offer.

Getting Prepared

The transition from HIS to HOPE marks an important chapter in the hospice care journey. Prepare for the transition with partners who understand the complexities and challenges that come with such significant changes. Specifically, work with a software and service company designed to ensure that your hospice team can seamlessly adapt to the HOPE framwork without sacrificing the quality of care.

About Curantis Solutions

From comprehensive training to state-of-the-art data management systems, we provide everything needed to make this transition as smooth and effective as possible. With Curantis Solutions, you can be confident that no matter how the standards evolve, you will always be at the cutting edge, providing compassionate, patient-centered care. t Curantis, we understand the unique challenges faced by hospice and palliative care organizations. Our commitment to providing exceptional support ensures that you can focus on what matters most—delivering compassionate care to your patients. We pride ourselves on our quick response times, we deeply listen to our clients, and are easy to get ahold of when you need us. When partnering with Curantis Solutions, we guarantee we have support you can depend on.

# # #

Vicki Goodman, RN, BSN, MHA is an accomplished healthcare professional with a strong background in post-acute care, SaaS sales. With a proven track record of driving revenue growth, Vicki has successfully orchestrated sales strategies and marketing initiatives with over 30 years of experience in the home health and hospice EHR industry. Prior to joining Curantis Solutions, Vicki was VP, Enterprise Sales at Matrix Care.

She is an RN and BSN graduated of East Carolina University and received her MHA from University of North Carolina at Chapel Hill. She credits a lot of her success to collaborating with product and marketing teams creating an unstoppable engine. We are thrilled to have her join the Curantis Solutions family and look forward to the continued growth under her leadership.

©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

Humana Thyme Agreement

Clinical

by Kristin Rowan | Mar 7, 2025 | Clinical, Hospice, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Palliative Care for Medicare Advantage Members

Cancer is one of the highest leading causes of death in the United States, second only to heart disease. The challenges for cancer patients are not only physical, but emotional and financial as well. The consequences of these challenges are often devastating to the patient and their families. Providing additional care, support, and pharmaceutical interventions through value-based care can improve patient outcomes and reduce out-of-pocket costs.

Thyme Care

Thyme Care is a Nashville-based cancer treatment center that operates in seven states. The centers provide not just treatment, but cancer care navigation, designed to work within the value-based framework, keeping the patient at the center of care. Thyme Care includes an oncology care team, a patient app with multiple resources and 24/7 access to support. Patient surveys track symptoms and reduce barriers to care. This approach combines cancer treatment and palliative care for whole-person cancer care support.

Palliative Care

Palliative care works alongside medical care to improve the quality of life for the patient, addressing physical, emotional, and spirtual needs. Strictly speaking, it is not medical care, and not specifically covered by most insurance plans. The out-of-pocket costs for palliative care can be extremely high, making this kind of care an inaccessible amenity for most patients.

Value-Based Care

Value-based care reimburses care providers partially based on patient outcomes and patient satisfaction. Providers also share the financial risk of care with health insurance companies. Care providers who can both improve outcomes and patient satisfaction can be reimbursed more through health insurance plans, which can cover the costs of palliative care, even when it is not explicitly covered by the plan.

Humana

Humana is a payer with plans for Medicare, Medicaid, and Individual/Family beneficiaries. The Medicare Advantage value-based care plans allow Humana to disperse payments for covered services in partnership with care provider teams across a patient’s care journey. The better the outcome and satisfaction, the more Humana can pay a provider for care. Better outcomes often means reduced hospital visits, a longer time at home before requiring skilled nursing facilities, and lower costs.

Humana Thyme Palliative Care Collaboration

The recently announced partnership between payer and provider will give eligible patients access to palliative care support as part of the whole-person cancer care navigation provided by Thyme. Humana patients can also receive, as needed, 24/7 virtual care, medication guidance, symptom management, chronic condition management, community-based resources, financial assistance, transportation, food assistance, and/or access to stable housing.

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news. She also has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Special Focus Program Ends

Advocacy

by Kristin Rowan | Feb 20, 2025 | Advocacy, CMS, Hospice, Regulatory

by Kristin Rowan, Editor

Special Focus Program Not Well Received

When the Hospice Special Focus Program (SFP) first appeared, the industry was told the program would help CMS identify and improve the performance of hospice providers that were struggling to meet quality standards. CMS developed the program to strenthen oversight, promote quality improvements, and ensure compliance for underperforming hospice agencies.

Soon after its inception and implementation in 2022, numerous concerns emerged. The National Alliance for Care at Home (then NAHC and NHPCO) voiced concerns over the program’s reliance on incomplete data as well as the potential for the program to unfairly targed providers in underserved communities.

Between February 2020 and January 2025, numerous state and national organizations have introduced Hospice Acts to Congress, given feedback to CMS on improvements to SFP, and filed lawsuits against the CMS.

Ramping Up the Opposition

In mid-2024, following the Council of States meeting, monthly opposition to the SFP became standard:

The McDermott Report highlighted significant flaws in the algorithm used for the program. Again, there was an objection over the use of incomplete and inconsistent data.
Bi-partisan Congress members sent a letter to CMS requesting revisions to SFP, criticizing outdated survey data and suggested that the quality metrics were inappropriately weighted.
Alliance CEO Steve Landers publicly criticized the implementation of SFP in his op-ed.
Representatives introduced Bill H.R. 10097 to delay SFP implementation, stating it would give CMS time to address the problems with the program and ensure fair application of standards for low-performing hospices without impacting quality programs.
The Texas Association for Home Care & Hospice; Indiana Association for Home & Hospice Care; Association for Home & Hospice Care of North Carolina; South Carolina Home Care & Hospice Association; and Houston Hospice filed a lawsuit challenging the SFP as unlawful and arbitrary.

CMS Backs Down

This week, CMS announced that it has paused the implementation of SFP for the calendar year 2025. The CMS statement say the pause will allow CMS to “further evaluate the program.” There is no mention of the opposition or the ongoing lawsuits.

The hospice special focus program page on the CMS website reads:

Effective February 14, 2025, implementation of the Hospice Special Focus Program for CY 2025 has ceased so that CMS may further evaluate the program. Please contact QSOG_Hospice@cms.hhs.gov for policy questions.

All additional information about the program has been removed from the website page.

Special Focus Program gets First Positive Feedback

For the first time since 2020, industry leaders are applauding a CMS move regarding SFP. The move is halting the program altogether, but at least its positive feedback.

“This decision is a positive move acknowledging that the current approach is not working as intended. The hospice community has long advocated for strong oversight and patient protections, but the SFP, as implemented, was deeply flawed, unlawful, and harmful to the very patients it was meant to protect.”

National Alliance for Care at Home

You can read the full statement from The Alliance in their press release.

Final Thoughts

It seems it is not often that CMS hears what the industry tells them. Reimbursement rates continue to drop, documentation is increasingly complex, and the industry has suffered from their misconceptions about what we need. This time, at least, there was enough pressure and advocacy from Congress and from you, the people who are impacted daily by their decisions, to cause them to rethink this program. Keep up the good work and continue to advocate for yourself and for care at home. Perhaps this is not the last time CMS will listen.

# # #

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news .She also has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Medicare Advantage Lowers Home Health Care Use

Hospice

by Kristin Rowan | Feb 6, 2025 | Hospice, Medicare Advantage

by Kristin Rowan, Editor

End-of-Life Care in Medicare Advantage vs Traditional Medicare

Using research from CMS, researchers from Mt. Sinai in New York and Brown University in Rhode Island studied the data of adults aged 66 and older who passed away and had Medicare coverage in their final year of life. Included in the study were people potentially eligible for home health care and not in a nursing facility, hospital, or hospice care setting. Data from close to 1.8 million people was analyzed. The researchers identified whether the participants received home health care and how many days of end-of-life care they received.

Home Health Higher in Traditional Medicare

Of the nearly 1.8 million participants, the average age was 82. 51.5% were female and 36.5% were enrolled in Medicare Advantage. In the final year of life, home health care use was recorded at 37.5% for MA enrollees and 41.7% for traditional Medicare.

When the researchers looked at different demographic groups within the data sets, home health care usage was higher in traditional Medicare in most groups. However, among American Indian and Alaska Native groups, Medicare Advantage had a slightly higher rate of home health use at 37.9% compared with 37.1% in Traditional Medicare.

Conversely, in the Asian or Pacific Islander demographic, home health use rate was 32.6% in MA and 41.8% in TM. Similarly, the rate of use among the Hispanic group was 33% in MA and 44% in TM. Following a similar trend, in the non-Hispanic Black group home health usage in MA was 38.8% compared with 42.9% in TM. Likewise, among the non-Hispanic White group, home health use in MA was 37.9% versus 41.5% for TM. For those of unknown race, usage was 36.1% in MA compared with 40.1% in TM.

Days of Care Lower in Medicare Advantage

Home health users across all racial and ethnic demographic groups enrolled as Medicare Advantage beneficiaries had fewer days of care in home health than those enrolled in Traditional Medicare. The stand-out group in this part of the research was those of Hispanic descent, who averaged 81.9 days in home health care in Medicare Advantage compared with 111.9 days in Traditional Medicare.

Implications

The researchers indicated some limitations in the study, namely that data was pulled from pre-covid patients because of the changes in home health during covid. The study should be repeated with post-covid data. One of the researchers received personal fees while serving as a senior advisor to CMS. Another received personal fees as a section editor for UpToDate. A third researcher reported receiving personal fees from Abt and UpToDate.

Despite these limitations, the implications of the study show that end-of-life care is not the same between Medicare and Medicare Advantage patients. Medicare Advantage is largely operating on a Value-Based Purchasing Model. The fewer services the beneficiary receives, the more money the primary doctor, hospital, and payer keep. It is not surprising, therefore, that MA patients get fewer services for less time. Patients who switch from Traditional Medicare to Medicare Advantage, especially if they are your patients, should be informed that they are still eligible for home health care and hospice care, but they may have to ask for it.

# # #

Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news .She also has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2025 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Good News for Veterans and Care at Home

Advocacy

by Kristin Rowan | Jan 9, 2025 | Advocacy, Hospice, Regulatory

by Kristin Rowan, Editor

Biden's Final Acts

With only a short number of days left in office, President Joe Biden has been making headlines. Not all of his final decisions have been met with absolute approval, but his latest one will make a difference for our veterans wanting Care at Home. On Thursday, January 3, 2025, President Biden signed into law the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act.

The Dole Act

The Elizabeth Dole Act improves upon much of the benefits, programs, and services provided by the Department of Veterans Affairs (VA). Some of these changes include providing protections for care agreements between veterans and clinicians, modifications to educational assistance programs and benefits, expansion of the Native American Direct Loan program, increases per diem rates for veteran transitional housing, and various administrative and oversight tasks.

Elizabeth Dole Home Care Act

The Elizabeth Dole Home Care Act is a bill within the larger act specific to home- and community-based services (HCBS). The home care act aims to enhance veterans’ access to the Program of All-Inclusive Care for the Elderly (PACE) nationwide. The new law also allows the VA to increase funding for HCBS. Prior to this, the VA was able to allocate 65% of nursing home care to home care services.

Additionally, the home care bill will provide support and benefits to caregivers of some disabled veterans, start a pilot to provide non-medical supportive care at home to veterans with limited access to home health aides, and increase access to HCBS for Native American Veterans.

The Industry Responds

The National Alliance for Care at Home responded to the landmark legislation, specifically siting section 301 of the bill, known as Gerald’s Law. Gerald’s is so named for a Michigan veteran who was denied his non-service related burial and plot benefit after he died at home while under VA hospice care. Gerald’s Law requires the VA to provide a burial and funeral allowance for veterans who were receiving VA hospice care in a home or other setting outside a hospital or nursing home.

“We are deeply grateful for the bipartisan support of Gerald’s Law and its inclusion in the Dole Act. This legislation ensures that Veterans and their families can choose hospice care in the setting that best meets their needs without risking the loss of crucial burial benefits. We thank Senators Moran, Tester, and Hassan, Representatives Ciscomani, Bost, Brownley, and Takano, and many others for their leadership, as well as President Biden for signing this important bill into law.”

Dr. Steve Landers

CEO, The Alliance

HCAOA, Leading Age, National PACE Association (NPA), and many others joined the Alliance in applauding Biden for signing the bill into law. They noted that providing care at home and in the community improves the quality of life for veterans and their caregivers. HCBS also come at a much lower cost than hospital and institutional care.

HCAOA said in a statement that the bill is “…a crucial victory for both veterans and their caregivers.” The President and CEO of NPA said the bill would dramatically increase options for veterans who want to age in place and that Congress can “…easily implement PACE for hundreds of thousands of additional seniors and their families.”

The VA has found that HCBS can delay or remove the need for nursing home or assisted living admission. Care at Home also reduces the risk of preventable rehospitalizations.

Final Thoughts

Once again, it seems the world is “discovering” that which we have known for ages: Home based care is better, cheaper, and more effective than institutional care. In the last few years, doctors and hospitals have figured this out and implemented hospital at home care. Now, the VA has finally figured it out as well. When this law takes effect, we as an industry will breathe a collective sigh when our veterans see better outcomes, their caregivers are better supported, the cost for their care decreases, and especially when our veterans enjoy a better quality of life in their final days without sacrificing the benefits to which they are so richly entitled.

One small step for veterans, one giant leap for Care at Home.

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Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news .She also has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

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