This shall be one of the most metal weeks of my life, in that I am seeing two of my bucket-list, must-see-before-I-die bands perform this week — Tool and Iron Maiden. I am quite excited.
I am also excited that October is right around the corner. This is my favorite month of the year. Autumn is my favorite season, and I am a big believer in pumpkin everything, soup, hoodies, apple picking, and all the suits and trappings of Fall. Also, Halloween time is the only part of the year that I can really shop for clothing or housewares.
Hospices may be a little less excited though, as Oct. 1 the U.S. Centers for Medicare & Medicaid Services (CMS) 2027 final hospice rule kicks in. This year, in addition to a 2.3% pay increase that doesn’t keep up with inflation or fuel costs, providers have some challenging new regulatory requirements to implement.
One big one is that hospice will have to provide an addendum to the election statement to each patient upon enrollment. Previously, CMS required providers to furnish these documents only upon request.
The addendum indicates what treatments and services the hospice will cover and which are considered “unrelated.” The requirement is part of CMS’ recent obsession with reducing non-hospice spending for enrolled patients. This is a real problem, but hospices generally are not the ones causing it. Other health care organizations are the ones who submit those claims. The hospice may not even know that the patient received services elsewhere.
The new addendum requirement, in my opinion, will put undue burden on providers, cause confusion for patients and families, and do little to curb non-hospice spending. CMS should not have mandated this.
Adding to the pressure is a Service and Spending Variation Index (SSVI) that critics say relies on a flawed methodology, potentially penalizing legitimate providers for non-hospice claims over which they have neither visibility nor control.
Providers also have no opportunity to review or correct the underlying SSVI data before it is made public, raising questions about the index’s effectiveness as a tool for program integrity.
The impetus behind this mistake is, again, reducing non-hospice spending, an issue which hospices cannot solve on their own regardless of what CMS tells them to do. If CMS wants to reduce that spending, they will have to look elsewhere in the healthcare system.
What do you think about these new requirements? How is your hospice preparing to implement them?
Notable quotes about death and dying from the two bands I’m seeing:
“This body holding me reminds me of my own mortality. Embrace this moment. Remember. We are eternal. All this pain is an illusion.” — Tool
“When my time has come to die, I will laugh and set me free. Upon my deathbed I will pray to the gods and angels say, ‘Now I’m safe and my soul’s set free. Hallowed be thy name.’” — Iron Maiden
It’s certainly a conundrum. I get the impetus for sure. In my 35 years as a hospice CEO I used to say we were among those on a short list that did it right. And that was hard. Hard to have contracts with all hospitals etc. for sure for covering appropriate therapy. On the other hand it seems just as bad or worse to discharge every patient that enters acute care. I would say that is a common practice among the more than 50 percent of hospices that report no GIP. The current benefit is tough to have with how today’s medicine is practiced. Pace is certainly more complex but the system makes sense and works. Very challenging. It would take quite a bit to make it all right. Hospice inpatient facilities solve so much of the concurrent billing and inappropriate interventions. Thanks Jim for the insights.