Posted December 7, 2022
NAHC needs our members to engage with your federal lawmakers to express opposition to a major hospice payment cap cut being included in any end-of-year legislative package that Congress is negotiating.
As is often the case with large, year-end spending bills, there are many programs and policies Congress wants to “stuff in” to an omnibus funding package before the close of the year. In order to pay for all these priorities, lawmakers must identify “offsets” to fund them. A significant reduction of the hospice aggregate cap, as has been recommended by MedPAC in the past, is being considered for one such “offset”. Recently, NAHC, in partnership with NHPCO and LeadingAge, sent a letter to Congressional leadership cautioning against using a cut to hospice funding in order to pay for other provisions in any upcoming end-of-year package. We need your help as hospice leaders to tell Congress that cutting the cap in a major and rushed way is bad policy.
NAHC has long been opposed to MedPAC’s cap cut recommendation. While the recommendation has been framed as a way to address outlier hospice program integrity concerns, in reality this overly blunt proposal is problematic for a number of reasons, including:
- Patient access to care could be significantly reduced: a major cap cut would create disincentives to serve patients that have a more unpredictable disease trajectory, such as those with dementia and organ failure, thereby disenfranchising entire categories of patients’ access to the hospice benefit.
- It could further exacerbate health disparities in hospice access and utilization: The individuals most likely to have their access to hospice impacted by the cap reduction (those with dementia and other neurological diagnoses) are also more likely to be from medically underserved communities that already have lower rates of hospice utilization.
- It may result in increased overall spending by Medicare: Any proposal that could limit hospice use, such as the cap reduction, may result in increased overall spending for Medicare, as patients who might have been served by cost-saving hospice instead utilize more expensive and aggressive care such as hospital, ER, and skilled nursing facility services. Recent research has shown that hospice use by Medicare beneficiaries is associated with significantly lower total health care costs across all payers, including Medicare.
A cut to the hospice cap is a crude tool to change hospice financial incentives and fails to take into consideration the many factors that contribute to variations in patient care needs. These factors include a more complex patient population for whom establishing an accurate six-month prognosis can be challenging, as well as greater variation in overall patient mix.
Additionally, modifications to the cap are not the right tool to address the most important program integrity concerns in hospice, such as the large and rapid growth in hospice licenses in some parts of the country that seem to be unrelated to the need for such growth. NAHC supports targeted efforts to address these concerns, and is eager to work with policymakers to root out true fraud in the system. To that end, we, along with NHPCO, NPHI, and LeadingAge, recently sent a letter to CMS highlighting some troubling licensure data that warrants closer investigation. We look forward to engaging deeper with CMS on this issue in the near future.
NAHC is committed to protecting hospice patients and their families, as well as the providers who care for them. We will continue to work with Congress and CMS to ensure that hospice oversight is effective enough to target the truly fraudulent and exploitative behavior of a small minority of operators, while not overly broad in such a way that puts undue burden on the vast majority of high-quality hospices delivering compassionate care to their communities every day.
Source: NAHC Report
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