What’s a PEPPER Report and why does my program need it?

Just over half of hospice organizations have downloaded their current Program for Evaluating Payment Patterns Electronic Report (PEPPER). Providers who aren’t accessing their report are missing vital information on quality and performance and red flags that regulators are looking at. NHPCO’s team shares their concerns and Judi and Carol discuss the opportunities in this underused but incredibly valuable resource.

Check out this latest NHPCO Podcast here!

FY2018 Hospice Medicaid Rates Announced

This week, CMS issued the FY2018 rates for the Hospice Medicaid benefit. Click here to see the official CMS notification of rates. The national rates are listed in the CMS notification memo.  The same wage index values apply to the Medicaid rates and the Medicare rates.  NHPCO has prepared the FY2018 Medicaid Hospice state/county rate chart, for download here. Each state has a tab across the bottom of the spreadsheet for ease in rate look up.  If you are interested in the calculations, look at the tab called “Wage-Nonwage Components” for detail on how the rates are calculated.

NOTE:  The FY2018 Medicaid rates are slightly different that the FY2018 Medicare rates.  Please ensure that billing staff note the difference.

Two issues of note with the FY2018 Medicaid rates.

  1. There is no allowance in the Medicaid hospice rates for the co-pay for respite care.
  2. There is no allowance in the Medicaid hospice rates for the co-pay for drugs.

Here are the national rates for hospices who HAVE submitted the required quality data:

Description Daily Rate Wage Component Non-Weighted Amount

Routine Home
Care (Days 1-60)

$193.03

$132.63

$60.40

Routine Home
Care (Days 61+)

$151.61

$104.17

$47.44

Service Intensity Add-On

$40.70

$27.97

$12.73

Continuous Home Care

$976.80

Full Rate =
24 hrs of care/$40.70 hourly rate

$671.16

$305.64

Inpatient Respite Care

$181.87

$98.45

$83.42

General Inpatient Care

$743.55

$475.95

$267.60

Below are the national rates for hospices who HAVE NOT submitted the required quality data:

Description Daily Rate Wage Component Non-Weighted Amount

Routine Home
Care (Days 1-60)

$189.22

$130.01

$59.21

Routine Home
Care (Days 61+)

$148.60

$102.10

$46.50

Service Intensity Add-On

$39.89

$27.41

$12.48

Continuous Home Care

$957.45

Full Rate =
24 hrs of care/$39.89 hourly rate

$657.87

$299.58

Inpatient Respite Care

$178.27

$96.50

$81.77

General Inpatient Care

$728.83

$466.52

$262.31

Any questions on the rates should be directed to regulatory@nhpco.org with Medicaid rates in the subject line.

NHPCO Applauds New Research Raising Awareness of Value in Earlier Access to Hospice

This NHPCO Press Release was just sent out, and I encourage all of our Advocates to share it on social media, and tag your Members of Congress! Or, email your Members of Congress with a link to this article and a copy of the below Press Release:

For Immediate Release:

(Alexandria, Va) – New research published in the current issue of the Journal of the American Geriatrics Society states that individuals who access hospice care often do so too late to fully benefit from this holistic model of care. National Hospice and Palliative Care Organization, the oldest and largest leadership organization working on behalf of hospice and palliative care providers applauds the research and attention it brings to issues involving when to best access hospice care.

A team of researchers from the Yale University School of Medicine looked at hospice enrollment for decedents from a cohort of 754 persons aged 70 and older who were enrolled in a larger longitudinal study.  Of the 562 patients who died during the study, more than 40 percent utilized hospice care in the last year of life; however, the median time spent under the care of hospice was less than two weeks.

Study researchers wrote, “In summary, hospice services appear to be suitably targeted to older persons with the greatest needs at the end of life, although the short duration of hospice suggests that additional strategies are needed to better address the high burden of distressing symptoms and disability at the end of life.

NHPCO’s current Facts and Figures Report indicates that 34.5 percent of patients died or were discharged within seven days of admission. In fact, the report shows that 61.5 percent of patients received care for 29 days or less, which may prevent patients and family caregivers from taking full advantage of the full range of services that the hospice team can offer. NHPCO stresses that hospice care is best suited for the final months of life, not just the final days.

Hospice is more than pain relief and symptom control. Hospice also provides emotional and spiritual support, training for family caregivers, and bereavement services to family for a year following the death of a loved one under hospice care.

Remarked Edo Banach, president and CEO of National Hospice and Palliative Care Organization, “Hospice and palliative care professionals have long known the importance of earlier access to the high-quality, interdisciplinary care that hospice makes available to those facing life-limiting illness.”

“Helping the public and the broader health care community – particularly physicians caring for patients with a non-cancer diagnosis – understand the many benefits of timely access to hospice care is an ongoing initiative at NHPCO. This study will certainly help raise important awareness and we offer our appreciation to the researches who have shared this important work,” Banach added.

Previous research has found that earlier access to hospice and palliative care services can prevent emergency department visits, hospitalizations, and stays in the intensive care unit – all of which can be distressing for those coping with serious and life-limiting illness.

Additionally, hospice works to help patients stay in the home if possible, which is the place that eight out of ten Americans would prefer to be at the end of life.

Timely access to hospice care can increase quality of life for patients and family caregivers. NHPCO suggests discussions of hospice care should take place earlier in the course of a serious illness, before hospice care might be necessary.

“Individuals must also ask their medical professions about hospice care and whether it’s appropriate and when the best time to think about accessing services should be,” explained Banach. “A question people can ask their physicians is: ‘Would you be surprised if I were to die within six months?’ – if the physician feels that this is a possibility, then a discussion about hospice should begin immediately.”

Resources to help people learn about hospice care are available on NHPCO’s CaringInfo.org website and via information, videos and tools from NHPCO’s public engagement campaign,Moments of Life: Made Possible by Hospice, at momentsoflife.org.


Timely access to hospice care can increase quality of life for patients and family caregivers.

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Contact:
Jon Radulovic
Vice President, Communications
Ph: 703-837-3139

Related media articles:

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Contact:
Jon Radulovic
Vice President, Communications
Ph: 703-837-3139

CMS Issues Hurricane Response Guidance

All of us at NHPCO are thinking of our hospice colleagues in Texas, Louisiana, and Florida and the patients and families they serve as they continue to struggle with the massive flooding and devastation of Hurricane Harvey and brace for the impact of Hurricane Irma.  For other hospices, this is a reminder to make sure that emergency preparedness policies and procedures are in place and planning has been done, since  EMERGENCIES AND NATURAL DISASTERS CAN HAPPEN ANYWHERE AT ANY TIME. 

  1. CMS Guidance for Hospice Operations
    CMS has issued guidance to providers in Texas and Louisiana in the aftermath of Hurricane Harvey, including Q&As specifically for hospices.Some providers may have questions about how care should be provided, what to do with patients who have relocated, and what timeframe requirements continue to exist.  CMS provides answers to many of those questions in the Q&A – the hospice section begins on page 17.  Here are a few Q&As published by CMS that provide examples of information for hospice providers:

L-2

QUESTION: If a hospice provider cannot provide care for its patients, can these patients transfer to another hospice provider?

ANSWER: Under the Social Security Act at § 1812(d)(2)(C) and CMS regulations at 42 C.F.R. § 418.30(a), a Medicare beneficiary may transfer from one hospice agency to another hospice for any reason once per election period. If a Medicare beneficiary has already utilized this one-time right to transfer but needs to move again because of a public health emergency, § 1861(dd)(5)(D) of the Act provides for a hospice agency to arrange with another hospice for the delivery of services in extraordinary circumstances. We would not deem a change in hospice under these circumstances to be a voluntary transfer under 42 C.F.R. § 418.30 (i.e., the beneficiary would still be entitled to a voluntary transfer after a transfer for “extraordinary circumstances”).

L-4

QUESTION: How should a hospice that temporarily receives a patient from another hospice handle administration of that patient’s care plan if the patient arrives with no alternate caregiver information, and/or the admissions officer believes that the patient may be legally incompetent to make health care decisions for him/herself?

ANSWER: Under CMS rules, the health and safety of the patient always comes first. The receiving hospice should complete an assessment of the patient to identify immediate needs and establish a plan of care with the interdisciplinary group (IDG). The receiving hospice should make every effort to contact the original hospice and/or attending physician to discuss the previously implemented plan of care and, if necessary, to determine if the patient is legally competent. If the receiving hospice has access to the plan of care established by the original hospice every attempt should be made to follow the plan if the needs of the patient are such that the original plan will provide the appropriate interventions.

There are other questions and answers related to Hurricane Harvey to hospices from CMS.  Click here to see the entire list.

2.  CMS Guidance for Hospice Quality Reporting

Hospices in the path of hurricane Harvey may have difficulty meeting the deadlines for submission of HQRP data.  Follow the directions provided on the HQRP website for more details on submitting an extension or exemption request.

Under current regulatory requirements, a hospice must request an extension/exception to the reporting of required quality data within 30 days of the event when there are extraordinary circumstances beyond the control of the hospice provider.  CMS does state, however, that “This process does not preclude CMS from granting extensions/exceptions to hospices not requesting an extension/exception when an extraordinary circumstance, such as an act of nature affects an entire region or locale.”

Quality Reporting Definitions

  1. Extraordinary Circumstances:
    Natural or man-made disasters preventing timely submission of quality data. A disaster may be widespread or affect multiple structures or isolated and affect a single site only.
  2. Extension:
    Submission deadline extended. CMS can extend submission deadlines for the specified deadlines for 30 to 45 days beyond the scheduled due date applicable to other facilities.
  3. Exemption:
    Submission deadline waived. CMS can exempt a facility from submitting quality data for the specified deadlines without impact on the Annual Payment Update.

Timeframes when Extension/Exception is Granted

When an extension/exception is granted, a hospice will not incur payment reduction penalties for failure to comply with the requirements of the HQRP.  Under the finalized process, a hospice may request an extension/exception of the requirement to submit quality data for a specified time period by submitting a written request to CMS.

This process does not preclude CMS from granting extensions/exceptions to hospices not requesting an extension/exception when an extraordinary circumstance, such as an act of nature affects an entire region or locale.

When an extension/exception to hospices in a region or locale is granted, CMS will communicate the decision through routine channels to hospices and vendors, including, but not limited to, Open Door Forums, ENews and notices on the CMS Hospice Quality Reporting website.

3.  HIPAA during a Disaster

The HIPAA Privacy Rule allows patient information to be shared to assist in disaster relief efforts, and to assist patients in receiving the care they need. In addition, while the HIPAA Privacy Rule is not suspended during a public health or other emergency, the Secretary of HHS may waive certain provisions of the Privacy Rule under the Project Bioshield Act of 2004 (PL 108-276) and section 1135(b)(7) of the Social Security Act.

If the President declares an emergency or disaster and the Secretary declares a public health emergency, the Secretary may waive sanctions and penalties against a covered hospital that does not comply with certain provisions of the HIPAA Privacy Rule which include:

  • the requirements to obtain a patient’s agreement to speak with family members or friends involved in the patient’s care (45 CFR 164.510(b))
  •  the requirement to honor a request to opt out of the facility directory (45 CFR 164.510(a))
  • the requirement to distribute a notice of privacy practices (45 CFR 164.520)
  • the patient’s right to request privacy restrictions (45 CFR 164.522(a))
  • the patient’s right to request confidential communications (45 CFR 164.522(b))

For Hurricane Harvey, President Trump has declared Hurricane Harvey a disaster and HHS Secretary Tom Price has declared a public health emergency.

Read more information about HIPAA during disasters from HHS.

View the Hurricane Harvey & HIPAA Bulletin: Limited Waiver of HIPAA Sanctions and Penalties During a Declared Emergency.

NHPCO Members:

Congressional Staffer Meets Hospice Patient and Family

Tony Kudner shared this piece about a visit the Seasons Hospice and Palliative Care Team in Orange County, CA had with staffer Chris Barwick from Senator Diane Feinstein’s office. Thanks for sharing your fabulous experience!

Last Thursday, Seasons Hospice and Palliative Care in Orange County, CA had a great meeting with Chris Barwick from Senator Diane Feinstein’s office. Chris was able to meet with several members of the Seasons Hospice and Palliative Care leadership team in a round-table  discussion that included the Medicare Hospice Benefit, the history of hospice, a brief overview of Seasons Hospice, and a short discussion around the Patient Choice & Quality Care Act.  From there, Chris met with the IDT, who shared some impactful patient stories and a few videos highlighting some of the best parts of hospice including Music Therapy and Camp Kangaroo (a Children’s Grief Camp). Chris and the IDT then engaged in a discussion about the hospice benefit and why it is important to CA patients and families.

Chris and the Seasons team then headed to a local memory care facility where Chris was able to witness a We Honor Veterans pinning ceremony.  Mr. Yasuda was admitted to care at Seasons two weeks ago and chooses to live in a memory care facility because his wife suffers from Alzheimer’s. This patient is of Japanese heritage and served in WWII and the Korean War, during which time his wife was living in an internment camp in the United States.  There were four generations of the Yasuda family present and it was a very moving ceremony. His love for country has never waivered and he became very emotional when presented with the certificate and was thanked for his service.   There was not a dry eye in the room.  The Yasuda family was so grateful for the service Seasons provided and honored to have a representative from the Senator’s office attend this special day.

The Seasons team then accompanied Chris to a home visit with a 98 year old patient who is suffering from end stage breast cancer.  This was a MSW visit where Chris was able to see where/how the Seasons team provides services in the home.

Chris had a lot of great  questions throughout the day that our site leadership was able to talk through with him.  As they drove him back to the office, they again discussed the Patient Choice & Quality Care Act. They asked him if the Senator would support this bill and if he would discuss cosponsoring this legislation with her.  We gave him a folder with some more information on hospice and the legislation we discussed, as well as Seasons specific info.

Overall, it seemed to be a very impactful and informative visit for him, and I am sure it will be an experience he will not soon forget!

Chris Barwick of Senator Diane Feinstein’s office meets with four generations of the Yasuda family, whose patriarch is currently under the care of Seasons Hospice, and was honored at this We Honor Veterans pinning ceremony.