FY 2022 Final Rule A discussion on Rates and Quality - Dr. Sherita Castille Clinical Pharmacist Partner - Hospice Pharmacy Solutions
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
FY 2022 Final Rule A discussion on Rates and Quality Dr. Sherita Castille Clinical Pharmacist Partner October 28, 2021
2 Objectives Overview of CMS FY 2022 Finale Rule Review the hospice wage index & payment updates Review the aggregated cap amount for FY 2022 Review revised Labor Share rate Discuss the finalized text changes to the addendum implemented on October 1, 2020 Overview of Quality Reporting Changes
3
Please Note
• Sherita Castille has no financial conflicts to
disclose
• The views, information, and guidance in this
webinar are those of the presenter
• The information may be incomplete and HPS
does not make any guarantees or warranties
concerning the information contained in this
resource
• If expert assistance is required, please seek the
services of CMS
4
Seeing the Big Picture
HOSPICE
• Providing patient centered, cost-effective care utilizing an
interdisciplinarian team approach
• Balancing hospice services versus palliative services
CMS
• Providing consistent regulatory guidance for cost
containment
• Increase coverage transparency and quality of hospice
providers
HPS
• Pain and symptom management consultations 24/7
• General drug information guidance: availability, costs,
cost-effective alternatives, adverse effects, etc.
• Educational Resources: Pathways to Success
2022 Updates
6
Summary at a Glance
On August 4, 2021, the Federal Register published the Final Rule on Hospice
Wage Index, Payment Rates and Aggregate Cap Amount for Fiscal Year 2022.
These Regulations are effective on October 1, 2021
• Rate increase of 2% for FY2022, effective October 1, 2021 – Economic impact of this rule is
estimated to be 480 million in increased payment to Hospice for FY 2022
• Updates to Labor shares of hospice payment rates and the Hospice Quality Reporting Program
• Clarity on text changes to the election statement addendum that was implemented on October 1,
2020
• The rule may permanent blanket waivers for Hospice agencies and were implemented during the
COVID-19 public health emergency providing revisions to Hospice conditions of participation (CoPs)
• Updated CAHPS to Consumer Assessment of Healthcare Providers and Systems (CAHPS) Star
ratings and addressed further development of Hospice Outcome and Patient Evaluation (HOPE)7
FY 2022 Hospice Payment Rates
With Quality Reporting
Code Description FY 2021 SIA Budget Wage Index Labor Share FY 2022 FY 2022
Payment rates Neutrality Standardization Standardization Hospice Payment
*(Includes Factor Factor Factor Payment Rates
rebase) Update
651 Routine $199.25 X 1.0003 X 1.0001 X 0.9995 X 1.02 $ 203.40
Home Care
(Days 1-60)
651 Routine $157.49 X 1.0005 X1.0009 X 0.9992 X 1.02 $160.74
Home Care
(Days 61+)
652 Continuous $1,432.61 X 1.0004 X 1.0006 X 1.02 $1,462.52
Home Care ($59.69/ hourly ($60.94/
Full Rate 24 rate) hourly rate)
hours of care
655 Inpatient $461.09 X 1.014 X 1.0059 X 1.02 $473.75
Respite Care
656 General $1,045.66 X 1.0019 X 0.9997 X 1.02 $1,068.28
Inpatient
Care8
FY 2022 Hospice Payment Rates
Without Quality Reporting
Code Description FY 2021 SIA Budget Wage Index Labor Share FY 2022 FY 2022
Payment rates Neutrality Standardization Standardization Hospice Payment
*(Includes Factor Factor Factor Payment Rates
rebase) Update
651 Routine $199.25 X 1.0003 X 1.0001 X 0.9995 X 1.00 $ 199.41
Home Care
(Days 1-60)
651 Routine $157.49 X 1.0005 X1.0009 X 0.9992 X 1.00 $157.58
Home Care
(Days 61+)
652 Continuous $1,432.61 X 1.0004 X 1.0006 X 1.00 $1,433.84
Home Care ($59.69/ hourly ($59.97/
Full Rate 24 rate) hourly rate)
hours of care
655 Inpatient $461.09 X 1.014 X 1.0059 X 1.00 $464.46
Respite Care
656 General $1,045.66 X 1.0019 X 0.9997 X 1.00 $1,047.33
Inpatient
Care9
Hospice Cap for 2022
• The aggregate hospice cap amount for FY 2022 is $31,297.61
• This amount is set by the Centers for Medicare and Medicaid
services each year. It is the maximum amount that a hospice will
be reimbursed for Medicare hospice service.
• The GIP cap limits the number of days of inpatient care for which
Medicare will pay to 20 percent of a hospice's total Medicare
patient care days
• If your overall per patient amount exceeds the annual cap amount
the difference must be repaid.
• If you have a significant number of patients who have long term
stays seek the guidance of CMS.Top 20 Principal Hospice 10
Diagnoses FY2019
Hospice Diagnosis Trends
G30.9 - Alzheimer's disease,
unspecified
G31.1 – Senile degeneration
of brain not elsewhere
classified
J44.9 – chronic obstructive
pulmonary disease,
unspecified11 Hospice Length of Stay Trends Fiscal Years 2016 to 2019
12
FY 2022 Hospice Payment Rates
With Quality Reporting
Code Description FY 2021 SIA Budget Wage Index Labor Share FY 2022 FY 2022
Payment rates Neutrality Standardization Standardization Hospice Payment
*(Includes Factor Factor Factor Payment Rates
rebase) Update
651 Routine $199.25 X 1.0003 X 1.0001 X 0.9995 X 1.02 $ 203.40
Home Care
(Days 1-60)
651 Routine $157.49 X 1.0005 X1.0009 X 0.9992 X 1.02 $160.74
Home Care
(Days 61+)
652 Continuous $1,432.61 X 1.0004 X 1.0006 X 1.02 $1,462.52
Home Care ($59.69/ hourly ($60.94/
Full Rate 24 rate) hourly rate)
hours of care
655 Inpatient $461.09 X 1.014 X 1.0059 X 1.02 $473.75
Respite Care
656 General $1,045.66 X 1.0019 X 0.9997 X 1.02 $1,068.28
Inpatient
Care13
Labor Share Updates for 2022
History: Did you know the last rebase for labor shares was in 1984? At the
time the benefit was calculated using the wage/non-wage proportions CMS
implemented in home health agency and skilled nursing facility cost.
• Continuous Home Care (CHC) and Routine Home Care (RHC) were 68.71%
• Inpatient Respite Care (IRC) and General Inpatient Care (GIP) were 54.13%
Goal: Rebase and revise LS cost based on the different levels of care. To
achieve this CMS evaluates 5 components that drive cost
• Direct Salaries and Contract • Overhead salaries
cost
• Overhead benefit cost
• Direct patient benefit cost
• Other patient care salaries14 Labor Share Updates for 2022
15 CLIENT PBM Training Quality Reporting
16 Addendum to the EOB
17
Addendum Clarification
CMS 2022 Final Rule will allow Hospice to furnish the
addendum within 5 days from the date of a beneficiary
or representative requests , if the request is within 5
days from the date of a Hospice election
Centers for Medicare
For example, if the patient elects Hospice on
&Medicaid Services June 1st and request the addendum on
June 3rd , the Hospice would have until
June 8th to furnish the addendum.
If the addendum is requested as care is proceeding, the
addendum must be provided within three days. This
was changed from the 2021 hospice proposed rule of
72 hours.18
2022 Final Rule Updates - Refusal to Sign
“If a patient or representative refuses to sign the addendum, the
Hospice must document clearly in the medical record (and on the
addendum itself ) the reason the addendum is not signed in order
to mitigate a claim denial for this condition for payment. In such a
case, although the beneficiary has refused to sign the addendum,
Centers for Medicare the ‘date furnished’ must still be within the required timeframe
&Medicaid Services (that is, within three or five days of the beneficiary or
representative requests, depending on when such a request was
made), and noted in the chart and on the addendum itself .”
CMS is clarified that if a non-Hospice provider requests the
addendum, rather than the beneficiary or representative, the non-
Hospice provider is not required to sign the addendum.”19
2022 Final CoP Updates – COVID 19 Waivers
Hospice changes were finalized to the hospice aide competency
evaluation standards were made permanent
Hospice aide competency test once performed by observing
Centers for Medicare a patient can now be assessed with a pseudo-patient, a
&Medicaid Services person trained to participate in a role play situation or a
computer- based mannequin device instead of actual
patients
If a concern is identified Hospice will be allowed to complete
a competency evaluation for the deficient skill and or related
skills instead of completing a full evaluation20
How to Stay Protocol Perfect
Know what is on the quality menu
o HIS – Hospice Item Set
o CAHPS (with Star Ratings on Compare Care)
o HCI – Hospice Care Index
o HVLDL – Hospice Visits in the Last Days of Life
o HOPE – Hospice Outcome and Patient Evaluation
(Coming Soon!)21
Quality Reporting Then
HQRP HIS CAHPS
Consumer Assessment
Hospice Quality Hospice Item Set of Healthcare Providers
Reporting Program
& Systems
• Patient level data collection • National Survey of family
tool developed by CMS members or friends
• Hospices are required to • Conducted monthly
submit an HIS Admission
and Discharge record for all
patients22
The HQRP Life Cycle
Annual Payment Update (APU) Calculations
Year 1: Data collection and submission
Year 2: Compliance determinations
Fiscal Year (FY): APU in effect23
Quality Reporting Now
Administrative Administrative
HQRP HIS CAHPS Data Claims Data Claims
HCI HVLDL
CMS is preparing for HQRP data to be publicly reported in January 2022. It will
contain additional quality measures that capture care across the hospice stay,
including a new measure called the Hospice Care Index. Additionally, the claims-based
Hospice Visits in the Last Days of Life (HVLDL) measure will be collected.24
Hospice Item Set
FY 2022 Updates
Seven measures from the Remember
Comprehensive Assessment The threshold for HIS is 90%.
Measure section was removed
Timely submission alone
Submission still required
does not equal compliance.
Removal of measures will be no
earlier than May 2022 CMS resource: Timeliness
Hospices that do not report HIS Compliance Threshold Fact
data will not meet the Sheet
https://orbit.texthelp.com/?file=https://www.cms.gov/fi
requirements for compliance les/document/timeliness-compliance-threshold-his-
submissions-fact-sheetaugust2021.pdf
with HQRP25
Hospice Care Index
Includes 10 indicators of quality that are calculated from claims data
Continuous Home Care (CHC) or Burdensome transitions (Type 2 )
General Inpatient Provided (GIP) live discharges from hospice
Gaps in nursing visits followed by hospitalization with the
Early live discharges patient dying in the hospital
Late live discharges Per – beneficiary Medicare
Burdensome transition (Type 1 ) spending
live discharges from Hospice Nurse care minutes per routine
followed by hospitalization and home care (RHC) day
subsequent hospital readmission Skill nursing minutes on weekends
Visits near death26
HQRP Quality Measure Summary
HIS
Comprehensive Assessment The proportion of patients for whom hospice preformed all 7 care
Measure at Admission and processes as applicable.
Discharge27
HQRP Quality Measure Summary
HIS
Comprehensive Assessment The proportion of patients for whom hospice preformed all 7 care
Measure at Admission and processes as applicable.
Discharge
HVLDL The proportion of patients that have received in-person visits from
Claims Based Registered Nurse or Social Worker on at least 2 out of the 3 final days of life.28
HQRP Quality Measure Summary
HIS
Comprehensive Assessment The proportion of patients for whom hospice preformed all 7 care
Measure at Admission and processes as applicable.
Discharge
HVLDL The proportion of patients that have received in-person visits from
Claims Based Registered Nurse or Social Worker on at least 2 out of the 3 final days of life.
HCI A single measure comprising of 10 indicators calculated from Medicare
Claims Based claims29
HQRP Quality Measure Summary
HIS
Comprehensive Assessment The proportion of patients for whom hospice preformed all 7 care
Measure at Admission and processes as applicable.
Discharge
HVLDL The proportion of patients that have received in-person visits from
Claims Based Registered Nurse or Social Worker on at least 2 out of the 3 final days of life.
HCI A single measure comprising of 10 indicators calculated from Medicare
Claims Based claims
CAHPS
Survey of family members or All 8 CAHPS measures are endorsed under NFQ #2651
friends30 Summary Overview of CMS updates Wage Index & Payment Rates Hospice Cap Amounts Rebase and Revised Labor Share Addendum Clarification Quality Reporting Changes
31 THANK YOU Questions?
You can also read
