Client Alert:  Hospice 2019 Final Rule Issued

August 29, 2018

The Centers for Medicare & Medicaid Services (CMS) issued its final rule, CMS-1692-F, which updates the Medicare hospice payment rates and wage index (Final FY 2019 Hospice Wage Index) for Federal Fiscal Year 2019 (10/01/18 - 09/30/19). Our professional staff has reviewed this rule in detail and compiled a summary of the most impactful updates.

The following rates apply to Medicare Hospice Payments with filed quality data:

Routine Home Care Payment Rates
October 1, 2018 - September 30, 2019
Days 1 - 60 - $196.25
Days 61+ - $154.21

Other Hospice Payment Rates: Effective 10/01/18:
Continuous Home Care $41.56 per hour, $997.38 for 24 hours
Inpatient Respite Care - $176.01
General Inpatient Care - $758.07

The following rates apply to Medicare Hospice Payments without filed quality data:

Routine Home Care Payment Rates:
October 1, 2018 - September 30, 2019
Days 1 - 60 - $192.39
Days 61+ - $151.18

Other Hospice Payment Rates: Effective 10/01/18:
Continuous Home Care $40.74 per hour, $977.78 for 24 hours
Inpatient Respite Care - $172.56
General Inpatient Care - $743.18

Service Intensity Add-on(SIA) Payment Rate

The SIA payment will be equal to the Continuous Home Care hourly rate multiplied by the amount of direct patient care provided by an RN or social worker, for up to four (4) hours total per day. The SIA will be paid in addition to the current Routine Home Care per diem. Effective 10/01/18.

2019 Hospice Aggregate Cap Amount

For Cap Year 2019 (October 1, 2018 - September 30, 2019), the cap amount is $29,205.44. It's also 0important to note that due to aligning the Hospice Cap Year with the Federal Fiscal Year, the self-reported Aggregate Cap Computation for Cap Year 2018 will be due by February 28, 2019, five months after the cap year end.

In addition to the aforementioned changes, CMS is now allowing two options to report drug charges on claims:

  1. Continue reporting, with corresponding NDC information, on separate line items (no longer mandatory); or
  2. Submit total drug and DME charges

Effective January 1, 2019, Physician Assistants can now serve as a hospice patients' designated attending physician. However, Physician Assistants may not serve as hospice Medical Directors, may not lead a hospice "interdisciplinary team", certify a beneficiary's terminal illness, or conduct the "face to face" encounter.

The following Hospice CAHPS Survey based measures still need to be finalized by CMS:

  • The proposal to continue treating the preferred language of the caregiver as a recommended variable
  • The proposal to continue requiring hospices to use CMS-approved vendors to conduct the CAHPS survey using one of the three approved modes
  • The proposal to continue to report eight quarters of data on Hospice Compare
  • The proposal to exempt small hospices from CAHPS data collection
  • The proposal to continue offering the "newness" exemption in future years

CMS Analysis of Cost Report Data

Based on a review of the 2016 Hospice cost reports CMS noted the following:

  • Routine Home Care (RHC) - Cost report data showed cost per day of $125, while the RHC 2016 payment was $161.89 per day.
  • Continuous Home Care (CHC) - Cost report data showed cost per hour of $52, while the CHC 2016 payment was $39.37 per hour
  • General Inpatient Care (GIP) - Cost report data showed cost per day of $850, while the GIP 2016 payment was $720.11 per day
  • Inpatient Respite Care (IRC) - Cost report data showed cost per day of $423, while the IRC 2016 payment was $167.45 per day

The updates in this final rule will have significant impact on the reporting for fiscal year 2019. We recommend reading the entire rule, which can be found here: CMS-1692-F. We hope you find this information valuable, and pleasecontact uswith any questions you may have.

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