Coalition Works Together to Present Hospice Concerns re: Proposed Changes

The National Coalition for Hospice and Palliative Care (Coalition) submitted comments on August 27th to the Centers for Medicare and Medicaid Services (CMS) on the hospice survey reform and enforcement remedies provisions contained in the Calendar Year 2022 Home Health PPS Proposed Rule, also known CMS-1747-P or the Home Health proposed rule. The Coalition formed a Hospice “Strike” Team and convened experts within our Coalition Member organizations to reach consensus on key concerns within this proposed rule.

“These comments reflect the consensus opinions and concerns amongst the broad hospice and palliative care field of providers that these significant proposed changes pose for patients and families”, noted Amy Melnick, MPA, Executive Director of the Coalition.

The Coalition focused on providing CMS with feedback and recommendations on several key areas:

•  Public Reporting: The Coalition is very supportive of public reporting and consumer transparency of hospice information, including through the standardization of the Accreditation Organization (AO) and State Agency (SA) survey process, where both AOs and SAs submit a form to report hospice survey deficiencies. However, the current form used, CMS-2567, in its current form, is unintelligible and of little to no use to the average consumer and must be changed.

•  Technical Expert Panel: The Coalition strongly recommends CMS convene a panel of interdisciplinary hospice experts, as well as patient and family representatives, to help implement this vast array of changes, including how best to present this new publicly available hospice data in a clear and coherent fashion.

•  Multidisciplinary Survey Teams: The Coalition is pleased that CMS is permitting hospice survey teams to include other members of the interdisciplinary team such as social workers and chaplains as second surveyors (primary must be an RN). This has been a prior Coalition recommendation. The Coalition includes several recommendations pertaining to the appropriate training and conflict of interest requirements of survey team members.

To read the entire set of Coalition comments click HERE.