04/04/2024

CMS Releases Hospice Rule, Includes HOPE Tool

On March 28, the Centers for Medicare & Medicaid Services (CMS) released the FY2025 Hospice Wage Index proposed rule. which included the most consequential reforms to hospice since the publication of the revised Conditions of Participation in 2008.

Over the past year, CMS has indicated that it would release of the long-awaited standardized assessment tool for hospice, which would set hospices on a path previously trod by Nursing Homes with their Minimum Data Set (MDS) and Home Health agencies with the OASIS tool.

Derived from the HOPE tool would be two new measures to be incorporated into the Hospice Quality Reporting Program (HQRP) which are:

1. Timely Reassessment of Pain Impact and
2. Timely Reassessment of Non-Pain Symptom Impact. The rule also proposes changes to the Hospice CAHPS tool.

Other changes embedded in the proposed rule include:

• 2.6% increase to the hospice wage index for FY2025, and an increase to the hospice cap to
  $34,364.85.
• Updates to the election statement and notice of election statement, and clarification who can
  certify a terminal illness.
• A proposal to transition from existing CBSAs to geographic delineation based on OMB statistical
  areas used in the 2020 census data.
• A request for information regarding payment for high-cost palliative treatments under the
  hospice benefit.
• Finally, CMS proposes HOPE-based process measures; the HOPE instrument; discuss updates to
  potential future quality measures; and propose changes to the CAHPS® Hospice Survey.

CMS has developed the following supportive materials:

 

• Fact Sheet on the proposed rule.

• Text of the proposed rule.

• Guidance Manual for the HOPE tool.

 

LeadingAge has completed a review of the proposals for LeadingAge members. This summary is not exhaustive; we encourage members to read the whole rule. This rule contains the proposal to implement the standardized patient assessment - the Hospice Outcomes and Patient Evaluation (HOPE) tool. The materials on the HOPE tool are largely separate from the rule. LeadingAge will be reviewing the HOPE tool materials in detail and seeking feedback on them from members. A separate summary of the additional materials will be available in the coming weeks. LeadingAge will convene members in at the April 9th meeting of the Hospice Member Network to discuss the rule and formulate comments. Join the Network or email Katy Barnett. If you have additional questions regarding the proposed rule, please reach out to Anne Shelley at ashelley@leadingageohio.org.