NHPCO Submits Comments to FY2018 Proposed Rule

Yesterday, June 26, 2017, NHPCO submitted its comments on the FY2018 Hospice Wage Index proposed rule (PDF). NHPCO thanks the Regulatory, Quality and Standards and Public Policy Committees for their input on this proposed rule, the many members who sent emails about reducing regulatory burden, those who listened to the Listening Sessions, and those who also sent comment letters to CMS.  86 comments were submitted.

Protecting Pediatric Palliative Care

A big hats off to Dr. Elisha Waldman in his recent opinion piece for the The Hill, “Access to Palliative Care needs to Stay in the New Health Bill.”  The piece is a strong argument for protecting pediatric palliative care, and he gives a good shout out to the Palliative Care and Hospice Education and Training Act.

I definitely recommend it for a read and a share, and also wanted to point out that writing to newspapers like The Hill, Roll Call, and Politico is a great way to get your issue in front of members of Congress. They really appreciate pieces from experts in their field (i.e. healthcare practioners), addressing the real- world implications of policy ideas. Give it a shot!

Additionally, share this article with your Members of Congress! Email it to them, post it to their Facebook page, and Tweet it to them! Tell them why you agree with Dr. Waldman, and how this would affect patients in your district.


Hospice Quality Reporting Program (HQRP) Launches Provider Preview Reports


The Hospice Provider Preview Reports with the quality measure results that will be used in public reporting on the Hospice Compare website are available now.  June 1 starts the 30 day window for review of the results for accuracy and submission of a formal request to CMS for review and correction.

Hospice Provider Preview Reports:
The Hospice Provider Preview Report is an important last step in the hospice public reporting process prior to the release of data on Hospice Compare in the summer of 2017.  The results included in the report are limited to quality measures based on HIS data submitted for Quarter 4- 2015 to Quarter 3-2016.  Results for quality measures based on Hospice CAHPS data will be available prior to inclusion in Hospice Compare in 2018.

The data used in the Provider Preview Reports are currently “frozen” but hospices may continue to submit corrections and additions to their HIS data for up to 36 months beyond the target date on a given assessment.  Changes in submitted data will be reflected in subsequent quarterly Provider Preview Reports and refreshes of Hospice Compare.

Access to the Preview Reports:  The Provider Preview Reports are available in the Certification and Survey Provider Enhanced Reports (CASPER) system.  Instructions for accessing the reports are posted on the Hospice Quality Public Reporting page of the HQRP website.  Scroll to the bottom of the page and select “Hospice Provider Preview Report Access Instructions” from the available downloads.

Corrections to Preview Report data: 
If a hospice identifies inaccuracies in its Provider Preview report a formal request for review should be submitted to CMS.  Requests for review may be submitted via email through 11:59:59 p.m. PST on day 30 of the preview period.  Instructions for submitting a request for review, including the information that must be included in the email, are detailed on the Hospice Quality Public Reporting page of the HQRP website.

If CMS concurs that corrections are needed, the results will be suppressed in Hospice Compare for the affected measures and the corrections will be reflected in the next quarter’s Provider Preview Report and refresh of Hospice Compare.

Members should direct questions to regulatory@nhpco.org.

Required Workaround for Hospices Submitting Routine Home Care (RHC) and Service Intensity Add-On (SIA) Payments at the End of Life

CMS recently issued SE17014 (PDF) to address hospice payment errors after the implementation of the January 1, 2016 hospice payment reform payment changes. They include payment errors for the two tiers of routine home care (RHC) and the service intensity add-on (SIA).

NHPCO has advocated on behalf of hospice providers to ensure that the guidance is clear and that the questions about how to proceed with this adjustment are answered.  As we continue to be in dialogue with CMS and the MACs on this issue, there may be additional clarifications.  NHPCO will immediately pass along any additional clarifications to NHPCO provider members as the information becomes available.

The following issues are covered in SE17014:

  1. History of the issue
  2. Credit balance reports
  3. Submitting adjustment claims now
  4. Using the Remarks field
  5. Timely filing deadline issues
  6. When to wait to submit adjustments
  7. Workaround for claims with a transfer in the benefit period

For additional questions, please contact your Medicare Administrative Contractor or regulatory@nhpco.org.

Members will find the full Regulatory Alert available on the NHPCO Regulatory Center online.

Being a Hospice Advocate

Today I thought I’d share an article written by one of my colleagues at NHPCO, Cassius Harris. Cassius has been an employee of the NHPCO Solutions Center for over nine years, assisting NHPCO Members and the general public with their questions about hospice. Here, he personalizes the experience of what being a hospice advocate means to him: 

As preparations for the summer Advocacy Intensive fall into place, NHPCO staff member Cassius Harris shares thoughts about the ways he advocates for hospice and palliative care in his daily work on the Solutions Center team.

Working in the NHPCO Solutions Center and supporting Infoline has taught me a great deal about the hospice field. From assisting NHPCO members to educating consumers, I have become quite knowledgeable about the hospice community and the many benefits that hospice and palliative care offer to patients and family caregivers. More importantly, working here has made me realize that I have become more than an NHPCO employee but something else – a hospice advocate.

Author Cassius Harris talks about how anyone, not just healthcare professionals, can be a hospice advocate.

When I started working here, I was under the impression that hospice advocacy only applied to those directly in the field – nurses, social workers, doctors, etc. Over time, I started questioning myself regarding my own feelings about hospice and end of life issues- Does hospice apply to me since my college degree is not in the medical field? Should it concern me since no one close to me is dying? Through my experiences, I have slowly come to the realization that anyone- regardless of profession – can be a hospice advocate if they have compassion for those at the end of life. Although having the educational credentials and background does help, advocacy does not require much except your willingness to have compassion for those that are at the end of life.Whether speaking to family members or friends, I find myself educating others on the basics of hospice because many people do not understand it’s benefits. Many people think it is a depressing subject that is not worth discussing. I have even met some people that mock it and joke about it. I explain to them that death is a serious issue and watching your love ones suffer in their last days can be unbearable.

When people ask me about my job I usually tell them that it is tad bit depressing but quite rewarding. Whether helping a consumer find a hospice in their local area or mailing out educational materials, I explain how wonderful it feels to promote an industry that can alleviate pain and suffering for caregivers and their loved ones.

With all of the information out there from websites to news articles, all one has to do is educate themselves and question their core values – how much do I care about people? What can I do to improve the quality of living at the end of life? Hopefully more and more people will become hospice advocates. All one has to do is look inside themselves and question their core values.


Learn more about the 2017 Hospice Action Network Advocacy Intensive, July 17-18.