CMS Issues Final Rule for Hospice Payments in FY 2024 –What it Means for Hospice Agencies

The Centers for Medicare & Medicaid Services (CMS) has issued its final rule updating hospice payments for fiscal year 2024. The rule includes a 3.1% increase in payments, which is an estimated $780 million in additional funding. Keep reading this post for more information on the rule.  

This is a significant increase in hospice payments; however, it is important to note that this increase does not fully offset the rising costs for many agencies. As a result, hospice agencies may need to make some adjustments to continue providing high-quality care in 2024. SimiTree is here to help guide you. Need to talk now? Call us at 866.839.5471 or fill out this form for a complimentary consultation and someone will reach out to you today. 

It is important for hospice agencies to start planning now for the changes that may be necessary in 2024. By making these adjustments early, hospice agencies can ensure that they are able to continue providing high-quality care to their patients. 

Need help navigating the changes? 

If you are a hospice agency that is concerned about the changes that are coming in 2024, we can help. We have a team of experts who can help you understand the final rule and develop a plan to adapt to the changes.  Call us at 866.839.5471 or fill out this form for a complimentary consultation and someone will reach out to you today. 

2024 Hospice Final Rule – What Does it Mean? 

Continue reading this quick article on what the CMS Hospice Final Rule means for your 2024 in hospice.  

Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, Hospice Quality Reporting Program Requirements, and Hospice Certifying Physician Provider Enrollment Requirements Summary 

Wage Index and Payment Rate Update 

Beginning October 1, 2023, the hospice payment update percentage for FY 2024 will be 3.1 percent for hospices that submit the required quality data and -0.9 percent (FY 2024 hospice payment update of 3.1 percent minus 4 percentage points) for hospices that do not submit the required quality data. 

The hospice cap amount for the FY 2024 cap year is $33,494.01, which is equal to the FY 2023 cap amount ($32,486.92) updated by the FY 2024 hospice payment update percentage of 3.1 percent.  

Telehealth in Hospice 

The language was amended to allow telehealth in hospice to continue until the end of the Public Health Emergency or December 31, 2024, whichever is later. 

Hospice Quality Reporting Program Updates 

Quality measures finalized since FY2022 updates are: 

Hospice Quality Reporting Program 

Hospice and Palliative Care Composite Process Measure—HIS-Comprehensive 

Assessment Measure at Admission includes: 

1. Patients Treated with an Opioid who are Given a Bowel Regimen
2. Pain Screening
3. Pain Assessment
4. Dyspnea Treatment
5. Dyspnea Screening
6. Treatment Preferences
7. Beliefs/Values Addressed (if desired by the patient)

Administrative Data, including Claims-based Measures 

Hospice Visits in Last Days of Life (HVLDL) 

Hospice Care Index (HCI) 

1. Continuous Home Care (CHC) or General Inpatient (GIP) Provided
2. Gaps in Skilled Nursing Visits
3. Early Live Discharges
4. Late Live Discharges
5. Burdensome Transitions (Type 1)–Live Discharges from Hospice Followed by Hospitalization and Subsequent Hospice Readmission 
6. Burdensome Transitions (Type 2)–Live Discharges from Hospice Followed by Hospitalization with the Patient Dying in the Hospital 
7. Per-beneficiary Medicare Spending
8. Skilled Nursing Care Minutes per Routine Home Care (RHC) Day
9. Skilled Nursing Minutes on Weekends
10. Visits Near Death

CAHPS Hospice Survey 

1. Communication with Family
2. Getting timely help
3. Treating patient with respect
4. Emotional and spiritual support
5. Help for pain and symptoms
6. 6. Training family to care for the patient.
7. Rating of this hospice
8. Willing to recommend this hospice

Hospice Outcomes & Patient Evaluation (HOPE) Update 

Per Medicare, the HOPE tool will be a component of implementing high-quality and safe hospice care for patients, both in Medicare and non-Medicare. HOPE would also contribute to the patient’s plan of care by providing patient data ongoing throughout the hospice stay. By providing data from multiple time points across the hospice stay, HOPE would provide information to hospice providers to improve practice and care quality. HOPE is intended to provide quality data to calculate outcomes and develop additional quality measures”. 

At this time, development of the HOPE instrument is ongoing.

Health Equity Updates 

After reviewing the comments received, Medicare has decided to convene a health equity technical expert panel to provide additional input to inform the development of health equity quality measures. 

Universal Foundation 

Per Medicare: “To further the goals of the CMS National Quality Strategy (NQS), CMS leaders from across the Agency have come together to move towards a building-block approach to streamline quality measures across CMS quality programs for the adult and pediatric populations. This “Universal Foundation” of quality measure will focus provider attention, reduce burden, identify disparities in care, prioritize development of interoperable, digital quality measures, allow for cross-comparisons across programs, and help identify measurement gaps”. 

Social Determinants of Health (SDOH) 

Medicare continues its efforts to align SDOH across all settings and might consider adding SDPH to the Hospice Quality Data Program.

CAHPS Surveys 

No changes were made to the CAHPS surveys in this final rule. 

Hospice Certifying Physician Enrollment 

Physicians who certify hospice patients as terminally must be enrolled in Medicare.  This will be implemented as of May 1, 2024. Current physicians not enrolled in Medicare will need to enroll or officially opt out of Medicare. 

Included in the FY 2024 Home Health Proposed Rule: 

• Proposed: Informal Resolution Dispute process for hospices to resolve disputes regarding condition-level survey findings. 
• Proposed: Special Focus Program conducted by CMS to identify hospices as poor performers and select hospices for increased oversight to ensure compliance with Medicare requirements. 
• Proposed: High-Risk Screening and Fingerprinting for new hospice provider enrollments and a 36-month rule for hospices undergoing a change in ownership. 

Tips to Navigate the Changes in the CMS Hospice Final Rule 

Here are some tips on how to navigate the changes in the CMS Hospice Final Rule: 

• Start planning early. The sooner you start planning for the changes, the more time you will have to make adjustments and ensure that you are prepared. 
• Understand the changes. Read the final rule carefully and understand the changes that will be implemented in 2024. 
• Talk to your team. Talk to your staff about the changes and how they will affect your agency. Get their input and ideas on how to navigate the changes. 
• Be flexible. The changes in the final rule may require you to make some adjustments to your operations. Be prepared to be flexible and adapt to the changes as needed. 
• Stay up-to-date. CMS will continue to issue guidance on the final rule. Stay up-to-date on the latest information so that you can make informed decisions about your agency. 

How SimiTree Can Help 

If your agency is concerned about keeping up with the rising costs and inflation in the industry, we are here to help you navigate these changes and the years to come so you can continue to provide quality care to patients. 

To recap, some of the key changes in the final rule include: 

• A 3.1% increase in the hospice payment update percentage. 
• A new payment cap of $33,494.01 per patient. 
• A requirement that physicians who certify hospice eligibility be enrolled as a Medicare provider or validly opted out. 

Agencies looking for guidance with these changes can turn to SimiTree.  

Let's work together to improve the health of your organization. At SimiTree, we balance financial expertise and clinical excellence to help our clients grow. How can we help you? Call us at 866.839.5471 or fill out this form for a complimentary consultation.  

Read more on CMS.gov: https://www.cms.gov/newsroom/fact-sheets/fiscal-year-2024-hospice-payment-rate-update-final-rule-cms-1787-f