On August 6, 2024, CMS published in the Federal Register, “Medicare Program; FY 2025 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, and Hospice Quality Reporting Program Requirements,” a final rule that becomes effective on October 1, 2024. This rule finalizes a 2.9% payment increase that applies to the payment rates for all four hospice levels of care and the hospice cap for fiscal year (FY) 2025.
The full increase will apply to agencies that met the submission requirements of the Hospice Quality Reporting Program (HQRP). Agencies that did not meet the required submission thresholds for HQRP, which include the Hospice Item Set (HIS) and Hospice Consumer Assessment of Healthcare Providers and Systems (Hospice CAHPS®) surveys, will be subject to a 4% payment reduction penalty. Adoption of the most recent Office of Management and Budget (OMB) statistical area delineations based on 2020 Census data also has been finalized, resulting in substantial changes to hospice wage index adjustments. We encourage hospice providers to review the rule in detail for more specific information that will impact their individual service areas.
HOPE Implementation
The HQRP will be updated with a new collection instrument that will replace the HIS. The Hospice Outcomes and Patient Evaluation, known as HOPE, will be implemented in all hospices no earlier than October 2025. This tool will collect data for two HOPE-based measures: 1) Timely Follow-up for Pain Impact and 2) Timely Follow-up for Non-Pain Symptom Impact. These two measures will determine if a follow-up visit occurs within two calendar days of an initial assessment of moderate or severe symptom impact. Data from these two measures will be publicly reported no sooner than FY 2028.
In addition to the new measures, agencies will need to plan for additional collection time points for HOPE that will be at admission, discharge, and defined HOPE update visits (HUVs) that must be completed in person by registered nurses (RNs). Symptom follow-up visits that must be completed within two calendar days may be performed by RNs or licensed practical/vocational nurses. CMS plans to continue to modify the tool and support further development of quality measures from HOPE data. Providers should start looking at available guidance and plan for implementation of the HOPE tool in their agencies, which will require training and updated processes to manage the time point collection and submission requirements for the new HOPE tool. Additional information can be found in the draft of the HOPE Guidance Manual on the CMS website.
Other Changes
The rule also finalized several changes to the CAHPS survey, which include the addition of a web mail mode that will allow for recipient notification of the survey via email with an attached link for ease of access to complete the survey. The CAHPS survey has been shortened and simplified with the removal, rewording, and replacement of some questions. The revised CAHPS survey will begin with April 2025 decedents. A draft of the survey instrument is available to view online.1
The final rule also provides some clarification of current policies related to the “election statement” and the “notice of election” in addition to adding clarifying language regarding hospice certification, which includes technical regulation text changes to the Conditions of Participation (COPs). These important updates are intended to provide additional clarity for providers to meet the conditions and payment requirements.
If you have any questions regarding this rule or other hospice industry matters, please reach out to a professional at Forvis Mazars.
- 1DRAFT Hospice Survey. https://www.hospicecahpssurvey.org/globalassets/hospice-cahps4/survey-instruments/revised_cahps-hospice-survey_for-website.pdf. August 2024.