The National Partnership for Healthcare and Hospice Innovation (NPHI) recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the hospice portions of the CY22 Home Health proposed rule. The proposed rule includes several provisions related to hospice accreditation organizations and enforcement remedies. Please find below a summary of NPHI's comments to CMS:

• NPHI is broadly supportive of the provisions laid out in the proposed rule and share many of CMS’s concerns regarding hospice quality of care. They believe that these new enforcement remedies, if appropriately targeted and effectively operationalized to focus on hospice bad actors, will result in an improved standard of hospice care across the industry and will allow for a more effective use of CMS’s limited resources.

• NPHI supports the use of a Technical Expert Panel (TEP) to determine the parameters for public reporting of survey data in a manner that is easily understood and of value to the public.

• NPHI supports the creation of a Special Focus Program (SFP) for those hospices found to be potentially placing patients at risk for poor care and encourage the use of a TEP to ensure that the SFP incorporates all the unique aspects of hospice care delivery in its creation and implementation.

• NPHI strongly supports efforts to ensure the consistency of survey results among State Agencies (SAs), and Accrediting Organizations (AOs), and encourage the use of surveyor staff with hospice industry experience and the requisite understanding of the core services to be delivered. 

For additional information on the proposed rule, please contact the WiHPCA office at wihpca@badgerbay.co.