On March 28, 2024, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule (CMS-1810-P) aimed at updating Medicare hospice payments and the aggregate cap amount for fiscal year (FY) 2025, aligning with existing statutory and regulatory obligations. This proposal also suggests adopting the latest Office of Management and Budget (OMB) statistical area delineations, which would alter the hospice wage index. Furthermore, it seeks to clarify current policies concerning the hospice “election statement” and the “notice of election” (NOE), along with introducing clarifying language regarding hospice certification. Additionally, the rule includes a request for information to gather opinions on implementing a distinct payment mechanism to accommodate high-intensity palliative care services.

HOPE Tool

Moreover, the rule proposes that Hospice Quality Reporting Program (HQRP) measures be collected through a new instrument called Hospice Outcomes and Patient Evaluation (HOPE). The HOPE tool is crafted to emphasize outcome measures instead of the process measures employed in the HIS system. According to the U.S. Agency for Healthcare Research & Quality, outcome measures gauge the effects of healthcare services or interventions on patients’ health status, while process measures signify the actions taken by a provider in patient care. It introduces two HOPE-based measures and outlines the planned evolution of this instrument. The proposal also seeks input on potential social determinants of health (SDOH) elements and offers updates on Health Equity, future quality measures (QMs), and public reporting requirements. Furthermore, it suggests changes to the Consumer Assessment of Healthcare Providers and Systems (CAHPS) Hospice Survey.

Payment Policies

In terms of Medicare Hospice Payment Policies, the proposed rule aims to adopt the most recent OMB statistical area delineations, allowing hospices affected by changes to their geographic wage index to apply a 5% cap on any decrease to the wage index from the prior year. The proposal also seeks feedback on implementing a separate payment mechanism for high-intensity palliative care services.

Annual Rate Setting Changes

Regarding FY 2025 Routine Annual Rate Setting Changes, the proposed hospice payment update percentage is 2.6%, resulting from a 3.0% market basket percentage increase reduced by a 0.4 percentage point productivity adjustment. Additionally, it suggests a statutory aggregate cap for the 2025 fiscal year of $34,364.85. Furthermore, it proposes revisions to the Hospice CAHPS Survey based on a mode experiment conducted in 2021 and seeks to align language discrepancies in hospice requirements for clarity and consistency. The proposed changes can be viewed in detail at the Federal Register at www.federalregister.gov/public-inspection/current.