VIEW FROM WASHINGTON. Judi Lund Person, MPH Vice President, Compliance and Regulatory Leadership, NHPCO

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1 1 VIEW FROM WASHINGTON Judi Lund Person, MPH Vice President, Compliance and Regulatory Leadership, NHPCO

2 Today we will discuss 2 Sequestration what s the latest New research on hospice cost savings Basic hospice data Rate cuts and federal budget challenges Hospice payment reform Quality reporting and additional data collection Audits, fraud and abuse Who we serve Veterans Patients in rural areas

3 Sequestration 3 What s the latest?

4 New Study on Hospice Cost Effectiveness 4 Author Amy S. Kelley, MD, MSHS Published in Health Affairs, March 2013 Findings: Most common hospice enrollment periods: 1 to 7 days, 8 to 14 days, 15 to 30 days, and 53 to 105 days. All enrollment periods significantly lower rates of: hospital and intensive care use hospital readmissions in-hospital death

5 New Study on Hospice Cost Effectiveness 5 Savings for both cancer and non-cancer patients Savings appear to grow as length of stay lengthens to 105 days, the end of the study period. Investment in the Medicare Hospice Benefit translates into savings overall for the Medicare system. If 1,000 additional beneficiaries enrolled in hospice 15 to 30 days prior to death, Medicare could save more than $6.4 million.

6 6 Basic Hospice Data

7 Patients Served by Hospice in the US ,800,000 1,600,000 1,400,000 1,200,000 1,000, , , , ,000 - Number of Patients Number of Patients Source: National Hospice and Palliative Care Organization, 2012

8 Number of Hospices Number of Hospices Number of Hospices Source: Centers for Medicare and Medicaid Services, 2011 Data Compendium

9 Days of Care Length of Service in Hospice Average Length of Stay Median Length of Stay Source: National Hospice and Palliative Care Organization, 2012

10 Percentage of days by level of care 10 Routine home care 97.3% General inpatient 2.0% Continuous home care 0.5% Respite 0.2%

11 11 Rate Cuts and Federal Budget Challenges

12 Rate cuts already in place FY2013 Rates Final hospital marketbasket update for FY % Less productivity reduction adjustment -0.7% Less additional hospice-specific productivity adjustment -0.3% FY2013 rate increase 1.6% The cap amount is set at $25, for the cap year ending October 31,

13 Sequestration impact, if % reduction for services provided on or after April 1, 2013 Bill at the FY2013 rate Contractor will apply 2% reduction with payments

14 Preparing your hospice for rate cuts 14 Streamline operations Staffing and staff caseloads Service area reductions Reduce services without affecting patient care Increase charitable giving

15 15 Estimated Median Profit Margin and Percent of Hospices with Negative Profit Margins,

16 Cutting Through the NOISE! 16

17 Opportunities for advocacy 17

18 HELP legislation 18 Working to reintroduce in 2013: Expand the list of health care professionals to conduct the face-to-face to include: Physician assistants Clinical nurse specialists Will expand the timeframe for completion of face-toface to up to 7 days after admission Will require a two year pilot of payment reform before finalizing Will require hospices to be surveyed every three years

19 19 Hospice Payment Reform

20 Hospice Payment Reform 20 ACA provision: Reform hospice payments no earlier than FY2014 Analysis of data currently underway CMS contractors continue to analyze Claims data Hospice cost reports Technical Expert Panel continues deliberations

21 Analysis of what? 21 Live discharges Rate of GIP utilization and LOS at GIP Drugs billed to Part D What are the drugs? Who are the hospices? Who are the pharmacies? Multiple diagnoses

22 Models 22 U-shaped curve Higher payments at the beginning of care Higher payments at the end of care Lower payments in the middle of care Other options Goal: to align payments with cost of services

23 23 Quality Reporting and Additional Data Collection

24 Hospice Quality Reporting 24 The data collection period is January 1 December 31 of each year Reporting is mandatory Data due April 1 of each year 2013 measures remain the same as 2012

25 Miss the deadlines? 25 Mandatory reporting Measures required no choice in what measures should be reported Miss the 2013 reporting deadlines? 2% cut in hospital market basket increase (hospice reimbursement rate inflation adjustment ) in FY2014

26 Patient level data 26 Mandatory data collection process being designed to collect data on individual hospice patients demographics, diagnoses, symptoms Used to collect data for future quality reporting Expect in 2014 or 2015

27 Experience of Care Survey 27 Similar to FEHC CAHPS survey being developed now

28 28 Hospice Fraud and Abuse

29 Auditors 29 MAC ADR requests ZPIC audits Data mining without provider knowledge Claims review in person Medicaid Integrity audits Other auditors gearing up Office of Inspector General US Department of Justice FBI

30 Other fraud and abuse activity 30 False Claims Act charges Whistleblower lawsuits Corporate integrity agreements Department of Justice involvement FBI involvement Possible civil and criminal action

31 Compliance is the Key 31 Answer these questions: Is this patient eligible? Does my documentation prove it? Has your hospice reviewed claims before submission? Has your hospice reviewed long stay patients for continued eligibility? THIS IS THE NEW NORMAL!

32 32 Concurrent Care

33 CMS Concurrent Care Demo hospice sites nationwide Focused on Medicare patients Patients can receive both curative therapies and hospice care concurrently CMS Administrator interested in pursuing

34 Concurrent Care for Children 34 Medicaid and SCHIP Mandatory coverage Eligible for hospice services All other services for which the child is eligible may continue to be provided

35 35 Other Issues of Interest

36 Hospice Care in the Nursing Home 36 Series of Office of Inspector General reports MedPAC analysis of hospice care in the nursing home suggested: Economies of scale Potential for duplication of services Suggested rate reduction CMS also analyzing volume, costs, visits by discipline and comparisons to hospice home care Continued area of vulnerability No action yet

37 OIG Reports and Work Plan 37 Medicare Part D and hospice Many drugs were paid for by Medicare Part D that may have been related to the terminal illness Marketing practices in nursing homes Hospice General Inpatient care

38 Part D and Hospice 38 OIG report issued in 2012 Some Medicare hospice beneficiaries receiving hospice care also had drugs paid for under Part D Scope of the problem: 198,543 hospice beneficiaries 677,022 prescription drugs through Part D Drugs should have been covered by the hospice? Part D paid pharmacies $33,638,137 Beneficiaries paid $3,835,557 in copayments Expect additional scrutiny for Part D payments

39 39 Who We Serve Veterans

40 National campaign to engage hospice providers to improve care for Veterans and their families at the end of life Collaborative effort developed by NHPCO with Department of Veterans Affairs Encourages partnerships between community hospices, state hospice organizations and VA facilities

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42 What You Can Do Join us! Over 1,600 hospices across the county are We Honor Veterans Partners Sign up online Learn about Veterans unique needs! Website, Networking Calls, Webinars and Technical Assistance Implement best practices! Military History Checklist Vet-to-Vet Volunteer Program Pinning Ceremonies and more Be recognized in your community! Logo, Press Release and Certificate provided Progress through the Partner Levels (One Four)

43 One out of every four dying Americans is a veteran Please step up to serve these men and women with the dignity and care they deserve. For more information: veterans@nhpco.org

44 44 Who We Serve Patients in Rural Areas

45 Opportunities for Change 45 Rural Health Clinics Feedback to CMS to reduce regulatory burdens for RHC physicians Critical Access Hospitals Collaborative work to ensure hospice contracts are possible Rural Hospice Research Project

46 46 Leadership into the future

47 47 Always remember.