Legislative Update: January 8, 2020
Hospice “Carve In” Demonstration Request for Application Released
The Center for Medicare and Medicaid Innovation (CMMI) released the Request for Applications (RFA) for the Value-Based Insurance Design (VBID) Hospice Component on December 19th. This track of the VBID demonstration allows Medicare Advantage Organizations (MAOs) to test incorporating or “carving in” hospice to their benefit packages.
The demonstration maintains the integrity of the hospice benefit but allows flexibility for plans to experiment with palliative care, concurrent care, and payment structure for in-network providers. We will be providing more information on the LeadingAge website and in the LeadingAge member community as we continue to analyze the proposal.
The RFA for the Medicare Advantage Organizations to apply to participate in the demonstration can be found here and is due on March 16, 2020.
Please contact Mollie Gurian, Director of Hospice, Palliative, and Home Health Policy at email@example.com with any questions or comments
Home Health and Hospice Open Door Forum
The next Home Health, Hospice & DME Open Door Forum is scheduled for
Wednesday, January 8, 2020 PM at 2:00-3:00 PM Eastern Time (ET).
Please call at least 15 minutes prior to the forum start time.
**This Agenda is Subject to Change**
- Opening Remarks
Co- Chair – Brian Slater, Center for Medicare
Moderator – Jill Darling (OC)
- Announcements & Updates
- Hospice benefit component of the Value Based Insurance Design (VBID) Model
- Hospice CAHPS announcement
- Hospice HQRP Updates
- Hospice Compare updates
- Hospice Compare:
- Home Health PDGM implementation status
- Home Health CAHPS update
- Updates and Announcements from the Home Health Quality Reporting Program
- Star Ratings Update
- Public Reporting Update
- Guidance Update-January Q&A’s will be posted January 21.
- OASIS Quarterly Q&A: https://qtso.cms.gov/providers/home-health-agency-hha-providers/reference-manuals
- Reminder: iQIES Update for HHAs
- Review Choice Demonstration for Home Health Services
**DATE IS SUBJECT TO CHANGE**
Next Home Health, Hospice & DME ODF: TBA
HOPE Alpha Testing
The deadline for recruitment to participate in alpha testing for the HOPE tool has been extended to February 21, 2020. Please see details below.
Abt Associates is currently recruiting hospice providers to participate in a field test (called an alpha test) of the new hospice patient assessment instrument, titled Hospice Outcomes & Patient Evaluation (HOPE). Data collection is anticipated to begin in late spring 2020.
The detailed recruitment announcement with additional information about the alpha test is available on CMS’s Hospice QRP Provider Engagement Opportunities webpage, at this link: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Hospice-Quality-Reporting/Hospice-QRP-Provider-Engagement-Opportunities.html
Those interested in participating, please follow the survey link:
https://www.surveygizmo.com/s3/5311824/HOPE-Alpha-Test-Application to complete the HOPE alpha test interest form.
Recruitment begins 11/22/2019 and ends 2/21/2020. Abt will notify each applicant on or about 3/5/2020 whether they have or have not been selected to participate in the HOPE alpha test.
Abt is seeking a representative group of hospices, with a range of characteristics, including ownership (profit, nonprofit); and rurality (urban, rural, both). Our goal is to include hospices that provide care for a wide range of patient populations, including people with cancer and non-cancer diagnoses, for example.
Scope of Practice Request for Feedback
We plan to respond to the request for feedback on scope of practice which was released on December 26th. The turnaround time for this request from CMS is short and is part of the larger “Patients Over Paperwork” initiative which is ongoing. This request is not an official Request for Information (RFI) and will be sent to an email address that has been and will remain open.
Given these factors, we will be providing comments that are framed by guiding principles and then a few specific recommendations in home health and hospice.
Our initial thoughts for recommendations are bulleted below and if you have ideas to add, please let us know. We will post our draft comments by Jan 10th for you to use them for your own submission (if you so choose) by January 17th but are not going to be engaging in major revisions after that given the short timeframe and the nature of the request.
- Expressing support for what CMS has already done to allow trained professionals to practice to the top of their license.
- Recognition of the state specific nature of professional licensure and complications therein.
- Recommendation that there be consideration of the future state of health care (including post-acute, long-term, and end of life care) delivery and what CMS’ role will be allowing professionals to practice at the top of their licenses regardless of the type of organization that employs them.
- Broad consideration of creation of waivers to scope of practice requirements in rural and underserved areas.
- Creation of a waiver under which hospices experiencing hardship in employing MSW-level social workers may obtain an exception to the social work supervisory requirement.
- Allow nurse practitioners (APRNs) and PAs to certify the terminal prognosis. (This requires a legislative fix)
- Allow PAs to complete the face to face recertification (currently APRNS can complete the face-to-face though a physician must do an attestation confirming the terminal prognosis to accompany the re-certification). (This requires a legislative fix)
- Allow Medicare payment for home health services ordered by a nurse practitioner, a clinical nurse specialist, a certified nurse-midwife, or a physician assistant. (This requires a legislative fix. Legislation has been introduced HR 2150/S 296).