The Centers for Medicare & Medicaid Services issued their final rule for CY 2022 which brings little change from the proposed rule. Just like we have seen in past years and after applying more recent data in the Market Basket Index, CMS reduced the annual update of payment rates from 2.3% to 2.0%. Under the final rule, hospice will see a 2% increase ($480 million) in FY 2022 payments. This is a result of the 2.7% market basket percentage increase reduced by a .7% productivity adjustment.
CMS also concluded that there will be an increase in the hospice payment cap, going up to $31,297.61 from the FY 2021 amount of $30,683.93, an increase of 2.3%.
As discussed in the proposed rule, CMS was looking to rebase and revise the labor shares for all four levels of care using 2018 Medicare cost report data for free standing hospice facilities. These amounts came out to 74.6% for continuous home care, 64.7% for routine home care, 60.1% for inpatient respite care and 62.8% for general inpatient care.
In terms of clinical data and quality measures for Hospice agencies, CMS has implemented a new measure in the Hospice Quality Reporting Program, Hospice Care Index. Ten quality indicators are calculated using claims data which will represent different aspects of a patient’s hospice care. Agencies that decide to comply with the quality reporting requirements will need to become even more familiar with the CMS Care Compare tool that unveiled last September. This tool allows the agency’s previously eight quality reporting sites to be rolled into a single resource.
It’s important for agencies to note, that patients, families, referral sources and even payers are beginning to pay more and more attention to this data when selecting a hospice provider. Also, failure to comply with the CMS quality reporting requirements will result in a 2% reduction to agencies annual payment.
As many were wondering about the changes due to the public health emergency, CMS did not make permanent the temporary measure allowing hospices to recertify patient’s via telehealth rather than a face-to-face encounter.
CMS did make the waiver related to hospice aide competency evaluations permanent in the final rule for 2022. This will allow hospice agencies to use “pseudo patients” during competency tests for hospice aides. This will mean that an individual or computerized mannequin device can stand in as the role of a patient rather than requiring contact with the actual patient.
Lastly, the rule gives clarification to regulation text changes on certain aspects of the hospice election statement addendum requirements. These changes don’t affect the timing of the hospice election statement or the decrease in payments when a statement is submitted untimely.
The final rule becomes effective October 1st, 2021.
Please contact us for reimbursement optimization support, hospice cap calculations, tracking and reporting requirements.