In The News

COVID-19 Health Care Staff Vaccination IFC-6: Presentation Slides and Video

Thank you for your interest in in the COVID-19 Omnibus Vaccine Rule (IFC-6). Thursday’s stakeholder call had a limit of 10,000 participants and we exceeded that number. Please accept our apologies.

CMS has posted the presentation slides and a recording of the stakeholder call for your convenience.

To view the slides, click here.

To view the video, visit: https://www.youtube.com/watch?v=xHA0zY1aC-Y

In addition to the resources above, CMS has prepared a frequently asked questions document, available here:

https://www.cms.gov/files/document/cms-omnibus-staff-vax-requirements-2021.pdf

 

Hospice Care in Nursing Facilities

Dear Barbara, Can you write about hospice care and the role of the hospice nurse/hospice team in long term care facilities?

The basic premise of hospice is to provide end of life care in the home. Because Assisted Living and/or Nursing Facilities are home for some people, it is appropriate that hospice care be available for residents in these facilities. The issue then becomes is there an overlap of services such as nursing care, bathing, or communication with a physician? Some facilities think there is an overlap and feel they can provide end of life care without the assistance of an outside (hospice) source. Other facilities create their own “hospice” team and provide their own kind of end of life assistance. Still other nursing facilities welcome the expertise of a hospice from outside their facility.

How can Hospice and Nursing Facilities work well together?

I think there are as many ways for a hospice to work with a nursing facility as there are hospices and facilities (all within medicare guidelines of course), but I will tell you what I consider the ideal relationship.

* A hospice team (RN, LPN, SW, HHA, Chaplain, & Volunteers) is assigned to an individual facility. Only that team works in their specific facility. You want everyone in the facility to know, recognize, and understand the hospice team. The entire nursing facility staff (right down to the receptionist) attends an inservice by that hospice team.

* Several educational sessions need to take place in order to clarify not only the role of hospice for the patient, family, attending physician, and facility, but also to provide end of life knowledge (pain management, comfort care, signs of approaching death, and nutritional guidelines) to these same people. Nursing facility regulations are basically in opposition to end of life care. 

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CY 2022 Home Health Final Rule – Survey and Enforcement Requirements for Hospices

To: NHPCO Provider and State Members
From: NHPCO Regulatory Team

Date: November 8, 2021

Summary at a Glance

On November 2, 2021, the Federal Register posted CMS-1747-F, the CY 2022 Home Health Prospective Payment System Rate Update Final Rule… Survey and Enforcement Requirements for Hospice Programs.

Important changes from the proposed to final rule:

1. Suspension of all or part of payments: NHPCO advocated for this provision to be limited to new admissions. In the final rule, CMS changed the language to read that the suspension of payments is for new admissions only.

2. Special Focus Program: NHPCO advocated for a Technical Expert Panel (TEP) to be convened to provide input prior to the development of any hospice Special Focus Program. In the final rule, CMS removed the regulatory language about the creation of the Special Focus Program and cited that revised language would be included in future rule making for FY 2024.

3. Surveyor conflict of interest: NHPCO advocated for ways that CMS could address surveyor conflict of interest. In the final rule, at 488.1110, CMS changed the language on surveyor conflict of interest to read: “surveyors must disclose actual or perceived conflicts of interest prior to participating in a hospice program survey and be provided the opportunity to recuse themselves as necessary.”

CMS has also issued the QSO-22-01-Hospice memo addressing the timeline for implementing the regulatory provisions of the CAA 2021 hospice provisions outlined in the CY 2022 HH final rule.

 

New PDGM Adjustments Make It Tougher to Reach ‘Medium’ or ‘High’ Functional-Impairment Levels

Home Health Care News | By Joyce Famakinwa
 
Home health operators have to navigate numerous regulatory and policy changes to stay in business.
 
Two major ones surfaced within days of each other last week. The U.S. Centers for Medicare & Medicaid Services (CMS) released the home health final payment rule on Nov. 2, then the federal government announced COVID-19 vaccination requirements for health care workers on Nov. 4.
 
Mary Carr, vice president for regulatory affairs at the National Association for Home Care & Hospice (NAHC), offered insight into both during a Monday webinar.
 
Among its provisions, the final rule made an adjustment to the Patient-Driven Groupings Model (PDGM), established a 3.2% increase to the home health Medicare rate for next year and finalized the nationwide expansion of the Home Health Value-Based Purchasing (HHVBP) Model.
 
The base payment rate for 2022 is going to be increased by a net market basket
 
index of 2.6%. The overall 3.2% rate increase is a substantial bump from the 1.8% CMS originally proposed in June.
 
“This was a nice surprise,” Carr said. “This is a reflection of an annual inflation update of 3.1%, reduced by 0.5% of productivity adjustment. And that’s where we get our net of 2.6%.”
 
Carr noted that this means the base 30-day payment rate under PDGM is increased from $1,901.12 to $2,031. 64.
 
“Now, if you calculate [it out], that’s going to be a little more than 2.6%,” she said. “The reason for that is there are some budget-neutrality gestures that get thrown back into the base rate. CMS has done some recalibration of the case-mix weights … and the wage-index budget neutrality. CMS always recalibrates the wage index annually.”
 
CMS’ recalibration of the case-mix weights was based on 2020 data, which raises some concerns, according to Carr.
 
“As I’ve noted, 2020 data was a little skewed with a public health emergency, but CMS insisted that this was appropriate and accurate,” she said.
 
Although there were changes to case-mix weights, low-utilization payment adjustment (LUPA) thresholds under PDGM remained the same.
 
CMS did make updates to functional-level points thresholds. This includes decreasing points on several of the OASIS scores and decreasing the threshold level for level of impairment.
 
“What this means is the same patient in 2021 that had a certain functioning level probably will have a lower score in 2022,” Carr said. “It’s going to take more functional disability to get to a ‘medium’ or ‘high’ using these new adjustments.”
 
Another change in the final rule was an update to the comorbidity subgroups. The “low” comorbidity group now has 20 categories total, an increase from 10 last year. The “high” comorbidity group is up to 85 interactive subgroups.

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Star Rating Coming for Hospices and Other CAHPS Updates

From the National Association for Home Care & Hospice (NAHC)

The Centers for Medicare and Medicaid Services (CMS) finalized the addition of a CAHPS hospice survey star rating for the hospice quality reporting program in the FY2022 hospice final rule, and the star rating will be publicly reported on Care Compare in August 2022. CMS is calling this star rating the “Family Caregiver Survey Rating Summary star” and hospices with 75 or more completed surveys over the reporting period will have their star rating publicly reported. The rating is the weighted average of the star ratings for each of the eight CAHPS hospice survey quality measures for a hospice.

Hospices will have the opportunity to see their CAHPS Hospice Survey Star Ratings in their official CMS Preview Report during the provider preview period prior to each update of Care Compare. Hospices will first see their Star Ratings in their Preview Reports during the preview periods for the February 2022 and May 2022 updates of Care Compare, which will be a “dry run.” CAHPS Hospice Survey Star Ratings will not be publicly reported in February or May 2022. The reporting period for the dry run is October 1, 2018 – December 31, 2019; July 1, 2020 – March 31, 2021.

The Star Rating for hospices is similar to Star Ratings in other provider types in that it consists of five stars with a range of the lowest score of one star to the highest score of five stars. According to the state and national distribution data posted on the CAHPS hospice survey website for the “dry run” period, the majority of hospices received a rating of 3-stars or 4-stars with 35% and 39% respectively.

CMS will provide more information on the star rating in its Home Health, Hospice & DME Open Door Forum (ODF) on November 10 (see previous NAHC Report coverage here). Until then, some information has been posted to the CMS CAHPS Hospice Survey website including:

NAHC is reviewing these documents and will provide a summary over the coming days.

In CAHPS Hospice Survey related updates, CMS recently posted the survey national percentiles for the measures for the Quarter 4 2018 – Quarter 4 2019; Quarter 3 2020 – Quarter 1 2021 public reporting period.  The average measure scores for each state for this same period are available as is the case-mix adjustment methods for CAHPS hospice survey measures document and the most recent CAHPS hospice survey response rate.

 
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