Late last month, the Centers for Medicare and Medicaid Services (CMS) released the 2024 Hospice Payment Rate Proposed Rule, which would update Medicare hospice payments, the aggregate hospice cap, and other hospice regulations.
Under the proposed rule, the hospice payment update percentage would be 2.8%, which is an increase of roughly $720 million in payments from 2023. This is a result of the 3% market basket percentage increase reduced by a 0.2 percentage point productivity adjustment.
The National Hospice and Palliative Care Organization (NHPCO) issued a statement in response to the proposed rule, which offered both their concerns and potential opportunities stemming from the proposed rule:
Concern:
- The 2.8% proposed rate increase for hospices is not enough to support the care hospices provide. Hospices are dealing with inflation rates that are at least twice that high, compounded by historical and ongoing workforce challenges. In 2024, pre-determined sequestration cuts will further reduce hospice reimbursement to a de facto increase of about 1%. Americans are increasingly choosing hospice for end-of-life care. Intentionally underfunding that care should be a non-starter.
Opportunities:
- CMS is using the proposed rule to advance hospice program integrity measures, curb fraudulent and abusive practices within the system, advance health equity, and increase hospice utilization. These efforts are in line with NHPCO’s ongoing work, including 34 program integrity recommendations made in January. NHPCO will work with the hospice community and CMS to help shape the following efforts:
- The proposed rule would require physicians to be enrolled in Medicare to certify and recertify patients for hospice care. If designed and implemented properly, NHPCO believes this measure may help identify physicians who are engaging (or potentially engaging) in fraudulent or abusive behavior, presenting a risk of harm to Medicare beneficiaries or are otherwise unqualified to certify or recertify beneficiaries for hospice.
- In this proposed rule, CMS announced it is soliciting feedback from providers via two Requests for Information (RFIs) – one on health equity in hospice and the other on hospice utilization, non-hospice spending, ownership, and hospice election. NHPCO welcomes the opportunity to provide feedback and is soliciting detailed comments from providers for both RFIs. CMS will have significant on-the-ground experiences from providers to inform these important issues around access, equity, and the integrity of the Medicare hospice benefit.
Public comments on the 2024 Hospice Payment Rate Proposed Rule will be accepted through May 30, 2023. WiHPCA will work with NHPCO and our other national stakeholders to submit public comments that reflect the thoughts and concerns of WiHPCA members and the greater hospice community across Wisconsin and throughout the country.
