Jim’s Notebook: Payment Risk for Nursing Home-Based Hospice Patients
I am back at work today after a week-long camping trip. The weather was beastly hot, but it was still glorious good fun.
Turning to hospice, the U.S. Department of Health and Human Services (OIG) has added a project to its work plan that will examine routine home care payments for hospice beneficiaries in nursing homes. The current status of the project is “announced,” according to OIG. So the agency is really just getting started.
But when completed it could have a significant impact on the hospice community. Essentially, OIG is looking at whether the personal care services that hospices provide to nursing home patients are duplicative. If OIG finds that this is so, the agency will likely recommend that the U.S. Centers for Medicare and Medicaid Services (CMS) reduce routine home care payments for patients in nursing homes.
“Paying the hospice the full routine home care rate that covers personal care services when these services are already required from the nursing home can undermine the efficiency of Medicare payments and add to the incentives that bad actors have to exploit the program,” OIG indicated in its work plan. “This review will determine Medicare payments for routine home care provided to hospice beneficiaries in nursing homes, estimate potential cost savings from reducing the payment to address the inefficiency in the payment structure, and examine practices of hospices with a high percentage of their beneficiaries in nursing homes.”
Though the issue is worth examining, the project kind of worries me. The prospect of payment reductions is troubling. Many hospices are also operating on a shoestring or are beset by margin compression and reimbursement pressures in which rate increases do not keep up with the rate of inflation or other rising costs.
Nursing home residents make up a significant contingent of hospice patients: about 14.5% according to the National Alliance for Care at Home. An across-the-board payment reduction could hurt hospices considerably, particularly those that have high percentages of nursing home patients in their census.
This review by OIG must take into account that regardless of what the nursing home is doing, hospices are nevertheless providing these personal care services. Careful examination may reveal that these services are redundant, but I think OIG needs to take a good look at the exact nature and frequency of personal care services provided by the nursing home and how they compare to those that hospices provide.
Hospice care is designed to be a comprehensive set of services that addresses multifaceted patient needs, including personal care. I don’t think we should deny nursing home patients that additional layer of support. Nor should we penalize hospices who care for those patients.
What do you think about this prospect? How might it affect your organization if it were to come to pass? Please drop a comment.