They’re baaaaaack!! And they’re co-sponsoring!

As the traffic on the roads here would indicate….Congress is back in Washington, DC. And thanks to all you in-district advocates, we are happy to announce that we already have two more co-sponsors on HR3037: The Hospice Care Access Improvement Act: Rep. Anna Eshoo and Rep. Dave Brat!

Yes I linked to their Twitter pages, and not their official House pages. Why? Because every one of you should tweet them your thanks! Believe it or not, legislators take tweets just as seriously as emails, and several tweets from citizen-advocates (especially those that reside in their district) can really get their attention! Plus, because it is public, it shows other people that advocates are out there working hard for hospice!

Not sure what to say? Just copy and paste any of my suggestions below!

General Thank You:

Thank you @RepAnnaEshoo & @RepDaveBrat for supporting #hospice by cosponsoring #HR3037! #hpm #eol @HospiceAction http://ow.ly/S6IfU 

Are you a constituent of someone who has co-sponsored HR 3037? Use this one!:

As a constituent and #hospice supporter, I applaud @(Find your Representative’s Twitter handle here) for cosponsoring #HR3037 #hpm #eol @HospiceAction http://ow.ly/S6IfU 

Has your Representative not cosponsored HR3037 yet? Use this one!:

Hopeful that @(Find your Representative’s Twitter handle here) will support #hospice patients and families by cosponsoring #HR3037 #hpm #eol @HospiceAction http://ow.ly/S6IfU 

I included a shortened link to our one page summary of the bill, and included the HAN Twitter account so we can retweet and favorite your tweets for maximum impact! Make sure you are within the 140 character limit though, and if you have to shorten it, you can delete the #hpm and #eol hashtags. Also feel free to compose your own tweets, but always keep it positive!

 

More Comment Letters from NHPCO!

Apparently no one told the CMS Comment Letter power(s)-that-be about the August recess. Or Labor Day weekend, for that matter.

On September 8, NHPCO submitted not one but TWO comment letters to CMS! Here is a short summary of the hospice-related elements in each, and NHPCO’s recommendations.

CMS-1631-P: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2016 

CMS has proposed reimbursement for the following two advance care planning services:

  1. CPT code 99497 (Advance care planning including the explanation and discussion of advance care directives such as standard forms (with completion of such forms, when performed), by the physician or other qualified health professional;
  2. Add-on CPT code 99498 (Advance care planning including the explanation and discussion of advance directives such as standard forms (with completion of such forms, when performed), by the physician or other qualified health professional

NHPCO Recommendations: NHPCO strongly supports the implementation of these two CPT codes by CMS, providing reimbursement for these services as approved by the CPT Editorial Panel and the AMA-RUC. We also ask CMS to make clear that completion of a particular form, such as an advance directive, during the advance care planning visit is not a prerequisite to billing for the service. Beneficiaries may want to initiate a discussion of advance care planning with their health care provider before they are ready to document their wishes on a standard form.

NHPCO Recommendation: NHPCO believes that advance care planning discussions, including planning for future events, goals of care, plans for treatment and the outcomes of treatment. and the completion of advance care planning documents should be done as desired by, and indicated for, the individual beneficiary, and would be appropriate at the Welcome to Medicare visit, an annual wellness visit, as well as when more serious illness presents itself.

NHPCO recommends that CMS recognize the important role of other members of the interdisciplinary team for their expertise and training in having advance care planning conversations, and look for ways to recognize the role of these team members, such as social workers, when ACP services are provided in settings outside the traditional physician office visit.

You can read the full NHPCO comment letter on CMS-1631-P online.

 

CMS-5516-P: Medicare Program; Comprehensive Care for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services

You might be asking yourself why NHPCO commented on the “hip and knee” rule. Well, NHPCO is provided comments on this proposed rule to since it put for a bundled payment for acute care hospitals furnishing lower extremity joint replacement (“LEJR”) services. Under this proposed model, hospitals would be accountable for the cost of Part A and Part B services, including hospice services, provided to a beneficiary during an “episode,” unless those costs were “excluded.”

For purposes of this bundled payment model, the “episode” includes the hospitalization for the LEJR procedure and the 90 day period following hospital discharge. Hospice services are on the list of services that would be included in the “episode” unless specifically excluded, and the proposed regulation specifying excluded services includes “Items and services unrelated to the anchor hospitalization, as determined by CMS.” Sounds like a relatedness issue again! How did NHPCO respond?

While we acknowledge that a Medicare beneficiary undergoing a LEJR procedure could end up in hospice care as a result of complications related to the procedure, we believe that will be uncommon, and we do not believe it is CMS’s intent, or consistent with the model, to hold hospitals accountable for all hospice care claims that may be incurred during an LEJR episode, even if the beneficiary’s eligibility for the hospice benefit is unrelated to the LEJR. … We ask CMS to clarify in the final rule that hospice services would be included in the LEJR only if the beneficiary’s terminal prognosis is related to the LEJR procedure.

The full NHPCO comment letter on CMS-5516-P is currently not publicly available. We we will update this page when the letter is posted on regulations.gov.

 

And if this doesn’t fulfill your regulatory fix, stay tuned! We’ll be bringing you conversation with NHPCO’s own Judi Lund Person, who is working on another comment letter, due next month!

NHPCO Comment Letter Physician Fee Schedule 2015

Things are cookin’ in Southern IN!

I’m super pumped to report that Amedisys Hospice of Jeffersonville in South Central Indiana had a fantastic visit with Lucas Phillips, a representative from the office of Congressman Todd Young. It was a textbook visit- they spent some time touring the facility, and talked about the impact hospice has on constituents from the IN-9 who are facing a life-limiting illness.

Lucas Phillips from Congressman Todd Young’s office visits with staff from Amedisys.

Amedisys Director of Office Operations Randy Hensley also spent a good amount of time talking through the We Honor Veterans program, of which their office is a Level 4 Partner!

I love hearing about interactions like this, and I have to give extra ‘props’ to Amedisys of Jeffersonville. You see, Randy came out to the 2015 Advocacy Intensive earlier this year, and he’s been on a tear ever since. He wrote a fantastic letter to the editor thanking Congressman Young for taking time to meet with him in DC, and how he and the rest of the Amedisys folks are strengthening that relationship back in the district. It’s textbook advocacy, and I love seeing it executed so well.

As always, if you’ve had a great in-district visit, let us know! We want to brag about you as well!

CMS Provides Payment Reform Memo to States

In  a recent memo to Associate Regional Administrators, CMS outlines the payment changes to Medicaid hospice programs to mirror the hospice payment reforms issued in the Hospice Wage Index Final Rule on July 31. The memo confirms for Administrators that, by law,

[t]he Medicaid hospice payment rates are calculated based on the annual hospice rates established under Medicare.

So why am I writing about a 5-page (inclusive of charts) memo? Quite surprisingly, NHPCO’s regulatory team–and even HAN–have received questions from many state departments of health and Medicaid programs on whether the new payment methods for the Medicare hospice benefit apply to their Medicaid programs. Or that they’ll wait until next year to implement changes because they are not prepared to make the changes by January 1, 2016. Or that their software vendors do not have the capability to become compatible with the new system in time. But the bottom line? By law: all 49 states with a Medicaid hospice benefit are subject to the same payment methodology changes as are Medicare hospice benefit providers. This is clarification that is long overdue.

But there’s another bottom line. What if this memo was sent last week regarding an October 1, 2015, implementation date as initially proposed? If Medicaid programs are concerned about a January 1, 2016 implementation date, what would have been the case if the 3 month delay was not instituted? What administrative havoc would have ensued? And most importantly, how would this confusion ultimately have impacted patients and families? As confusion across the country may ease as a result of this memo, at least states have 3 more months to get ready for these changes.

So reach out to your own Medicaid offices, or your contacts with contacts at your Medicaid office, and spread the word about these changes. And let NHPCO know how your state is preparing (or not) for the payment system changes. You are the ones with these relationships, NHPCO is relying on you to help get the word out. Hear anything positive, confusing, or troubling? Email regulatory@nhpco.org and let our regulatory team know!