WASHINGTON, D.C. – The National Partnership for Healthcare and Hospice Innovation (NPHI) recently shared detailed feedback with Congressman Blumenauer’s staff regarding his newly released Hospice CARE Act of 2024 discussion draft. A thorough response addresses each provision of the draft, and a high-level summary of the input is detailed below. The complete response can be reviewed here.
- NPHI provided broadly supportive feedback on the majority of program integrity provisions included in section two of the discussion draft. Specifically, the feedback addresses the following:
- Subsection (e). Independence of Attending Physician: We share the concern behind this provision that there are physicians certifying the terminal illness of patients who may have ulterior motivations related to their personal financial relationship to the hospice provider. While we appreciate the intent behind this provision we are concerned about the practical impact of its implementation. We provided a series of plausible alternative concepts to address the issue.
- Subsection (n). Requiring Face-to-Face Encounters Before Recertifications of Terminal Illness: While we support efforts to ensure patients have consistent access to physicians while electing hospice, we have concerns about the feasibility of requiring new visits for certain providers, especially those operating in rural areas or who may have other extenuating circumstances, such as ongoing staffing shortages. In response to those concerns, we provided multiple ideas for how to modify the provision to provide hospices with more flexibility.
- Section three (payment reform) is not as comprehensive or as likely to advance in the short-term as section two, however, we are excited to see Congress acknowledge the challenges facing the Medicare hospice benefit and non-profit providers. Specifically, we stated that:
- Subsection (a). Adjusting Payments for Hospice Care: NPHI has consistently advocated for reform to the Medicare hospice benefit reimbursement methodology. We believe the current payment framework is outdated, encourages manipulation, and does not adequately reimburse the providers caring for the most complex patients. As such, we welcome Congressman Blumenauer’s proposal to address these challenges via the proposed reforms to the routine home care payment. Our response poses several questions about the payment reforms proposed.
- Subsection (b). Wage Adjusting Caps: We are supportive of efforts to reform the wage index and aggregate cap methodologies and this proposal is a strong starting point. However, Congress should consider going further by removing hospice from the current hospital-based wage index determination process and creating a separate methodology, as recommended by MedPAC, by which to calculate the hospice wage index. More information on NPHI’s proposal can be found here.
Continued engagement with Congressman Blumenauer’s team is anticipated as the next steps with his draft proposal are developed. For any questions, comments, or concerns about these proposals or input that didn’t make it into this response, please reach out to NPHI’s Policy Director, Ethan McChesney: emcchesney@hospiceinnovations.org.
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