Posted Wednesday, September 6, 2023
NAHC filed comments yesterday in response to CMS’ 2024 home health rule, telling CMS that some aspects of the hospice Special Focus Program are flawed and need to be fixed to ensure accuracy and fairness.
In response to reports from the Office of the Inspector General (OIG) in July 2019 on hospice quality, Congress required the creation of an SFP in the Consolidated Appropriations Act of 2021. If it is designed like similar programs in other settings, the SFP will be able to impose enforcement remedies, such as fines, reimbursement suspension, appointment of outside management, revocation of a provider’s Medicare certification, on hospices that perform poorly on surveys. Hospices could be surveyed every six months instead of every three years, as is the current practice.
To be clear, NAHC strongly supports the SFP’s goal to “identify hospices as poor performers, based on defined quality indicators, in which CMS selects hospices for increased oversight to ensure that they meet Medicare requirements” and believe the appropriate quality indicators are essential in identifying hospice providers that would most benefit from the program.
NAHC asks that CMS work with the existing SFP Technical Expert Panel (TEP) to
- improve the SFP algorithm methodology prior to its planned implementation on January 1, 2024,
- implement a nationwide pilot of the updated algorithm with all hospices, during which SFP results will not be publicly posted, and hospices will be provided interim reports of their performance ranking under the updated SFP algorithm metrics.
This may require a delay in implementation and that CMS issue a new proposed rule with the modified algorithm to give stakeholders the opportunity to comment.
The consequences of being selected for the SFP are severe,” NAHC writes in the comments, “which is why the selection criteria must be designed to identify the subset of hospices that are truly the poorest performers and most in need of remediation to address quality concerns. An interim performance period (or preview period) would help providers understand the algorithm, learn how their performance compares to others nationally, and identify where they need to target improvements to ensure high-quality care.
“The centerpiece of the proposed hospice proposed rule is the Special Focus Program that sets standards for enhanced oversight of certain hospices, a measure that NAHC helped to champion before Congress,” said NAHC President William A. Dombi. “We sincerely hope that CMS refines those standards expeditiously so that we can see the benefits of that oversight as soon as possible. Hospice patients deserve only the best care.”
As currently constructed, we are concerned that the SFP algorithm would not only miss the opportunity to improve truly poor-performing hospices, but also could unfairly identify higher-performing hospice programs based on factors that are not as germane to patient and family care quality and satisfaction
(e.g.., size of the hospice). The ramifications of a poorly targeted selection process could inadvertently lead to access issues for beneficiaries and their families.
Source: NAHC Report
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