FY 2025 Hospice Proposed Rule
This post is by Judi Lund Person, MPH, the newest member of the Schramm Consulting Team.
As it does every spring, on April 4, 2024 the Federal Register published the final version of CMS 1810-P, the FY2025 Hospice Wage Index proposed rule. Upon first reading, my internal reaction was, “Finally!”
Finally, we get the released HOPE tool for quality reporting. Finally, we get an improved version of the CAHPS survey, along with a new web-mail mode that should improve response rates. Finally, CMS proposes the clarifying language that hospices have been asking for in connection with physician designees and the Election statement versus the Notice of Election (NOE).
Of course everyone’s first question will be about the proposed rates for next year. CMS proposes a modest 2.6% rate increase for hospices that participate in quality reporting in FY2025. Those hospices that are not participating in quality reporting actually would see a decrease of 1.4% (or a 4% reduction in payments from FY2024).
As mentioned above, another highlight is the proposed Hospice Outcomes and Patient Evaluation (HOPE) tool, with an effective date of on or about October 1, 2025. CMS proposes that every hospice will now begin to adapt to this data collection instrument which will replace the Hospice Item Set (HIS). Once HOPE is implemented, CMS proposes to implement two new process quality measures, no earlier than CY 2027. They include Timely Reassessment of Pain Impact and Timely Reassessment of Non-Pain Symptom Impact.
Something I’m especially pleased to see is that CMS has also proposed changes to the CAHPS® Hospice Survey. There will now be a new web-mail mode for survey distribution and completion. So many of us are very happy to see a web version of the survey, as we believe that it will help with response rates. In addition, the revised survey is shorter and simpler than the current survey, and includes new questions on topics suggested by stakeholders. By my first reading, these changes will meaningfully improve the survey’s ability to capture the family and patient experience.
And for those of us who have been confused about the role of the physician designee and a disparity between the Medicare’s regulations at §418.102 versus §418.22, I cheer for the clarity CMS has proposed. I’m also happy with the new clarity for the difference between the election statement, which the patient signs, and the Notice of Election, which the hospice submits.
Of course this is the proposed rule, so some things may still change before the release of the final rule late in the summer. And you have the opportunity to make your comments known! I encourage hospice leaders to check out the proposed rule for themselves, think about how this applies to your hospice, and feel free to submit comments if you have them. To do so, go to www.regulations.gov and look up “CMS-1810-P”.
Judi Lund Person, MPH, is available for board and staff education sessions on regulatory topics and the strategic impact of hospice payment policy. Contact us at info@schrammconsulting.com to inquire about remote briefings or in-person appearances. See her full bio on our Team page.