Palliative Care Via Home Health: Good, But Very Constrained
I am gearing up for a week-long camping trip starting next Tuesday, so I’m in a mad scramble to write all my stories in advance as well as prepare for the excursion itself. Thus, this has been a busy week. I hope everyone out there is also taking time to enjoy the summer.
The camp out will have a Viking theme this year, complete with aligned art pieces displayed onsite, a “Brunch of the Gods,” theme-appropriate garb and an axe throwing yard made from wood and chain link that we will assemble when we get there. I am looking forward to it!
But right now I have other things to say.
In its 2027 proposed rule for home health agencies, the U.S Centers for Medicare & Medicaid Services (CMS) clarified that those providers can use certain billing codes to cover community-based palliative care.
This action by CMS could help improve access to palliative care in the United States, which is sorely needed. However this impact could be very limited due to the structure of the home health benefit.
Important to note is that CMS isn’t really doing anything new here. These billing codes for palliative care already exist and home health agencies can already use them. The language in the proposed rule was little more than a reminder of that.
What will really determine how significant this might be is subregulatory guidance forthcoming from CMS that will provide further details on how providers should use the codes and in turn offer palliative care.
One issue is that patients will have to meet the eligibility requirements for home health care before they can receive palliative services from those agencies. This means that the patients will have to be homebound. The many patients who are not homebound but could benefit from receiving palliative care are excluded (though they may receive those services in another setting or from a different type of provider, like a hospice).
Second, hospices, which provide about 50% of palliative care in the United States according to the Center to Advance Palliative Care, can’t use these billing codes unless they have a Medicare-certified home health business. The hospice sector is particularly rich with palliative care expertise, and they can’t get involved through this home health benefit.
Third, home health agencies really aren’t incentivized to provide comfort care that is essentially non-curative. The quality measures for which they are accountable are largely improvement measures that indicate whether “grandma” is making progress. A palliative care patient might not show those signs of improvement, which could impact home health agencies’ quality scores.
The question also remains as to whether home health agencies have the capacity and expertise to effectively provide palliative care, given current workforce constraints and the limited availability of training to provide those services. Can they provide the full scope of interdisciplinary palliative care? Will the reimbursement support that?
An additional unanswered query is: What do we mean by palliative care?
A common adage says, “If you’ve seen one palliative care program, you’ve seen one palliative care program.” CMS to date has not prescribed a care model that indicates what “palliative care” should look like through this benefit. What actually will these patients be getting?
I hope that some of these questions can be addressed through the forthcoming subregulatory guidance, but of course that remains to be seen.
More details will come in a Hospice News piece slated for tomorrow, but I wanted to share my opinion on this CMS action here. What is your opinion on this?