CMS Adopts Hospice Final Rule for Fiscal Year 2012
The Centers for Medicare and Medicaid Services (CMS) issued its final regulation for hospice for fiscal year (FY) 2012. Click here to read the final hospice rule.
The final rule includes the hospice wage index for FY 2012, revisions to the hospice requirement for face-to-face encounters for recertification of a patient’s terminal illness, and provisions for implementation of a hospice quality reporting program. The measures being adopted in this final rule for the FY 2014 program include one measure endorsed by the National Quality Forum related to pain management, and one structural measure that assesses whether a hospice administers a Quality Assessment and Performance Improvement (QAPI) program containing at least three indicators related to patient care. Hospices will be required to begin collecting quality data in October 2012, which must be submitted in 2013. Hospices may also voluntarily begin collecting data on the QAPI measure in October 2011 for submission in 2012. Hospices failing to report quality data in 2013 will have their market basket update reduced by two (2) percentage points in FY 2014. The final rule is effective October 1, 2011.
CMS Press Release: Final Wage Index Changes for Medicare Hospices Increase FY 2012 Payments by 2.5%
AOTA submitted comments on the proposed hospice rule regarding its concerns about patient access to occupational therapy in hospice care, as well as provider education about the benefits that occupational therapy can provide to hospice patients. We encouraged CMS to adopt quality measures that are reliable; not overly burdensome; and that measure all areas integral to the needs of the patients addressed by hospices, including the provision of occupational therapy. AOTA cautioned CMS on using the CARE tool as an assessment instrument in the hospice setting, which it was not developed for. AOTA recommended that CMS refine the CARE tool and test its appropriateness to reflect this different use for gathering quality data. AOTA also urged CMS to continue exploring and expanding the list of quality measures to address all areas vital to the needs of hospice patients, including occupational therapy.
In the final rule’s response to comments, CMS acknowledged that “the CARE in its current form would not meet the needs of hospice patients or providers, and that revisions including the addition of care domains and items would be required to make CARE hospice-appropriate.”