Many home-based care providers tend to offer both home health and hospice services. Thus, home health leaders pay close attention to proposed rules in hospice.
Home health providers are still weeks away from getting a glimpse at their proposed rule for 2024.
In terms of the main provisions, the proposed rule for hospice doesn’t contain a large number of policy changes this year, according to Theresa Forster, vice president of hospice at the National Association for Home Care & Hospice (NAHC).
“We’ve got the payment update, which they’ve addressed in a relatively standard way, it nets out at 2.8%,” she told Home Health Care News. “That is, of course, a proposed element. We know that the update rate generally changes between what’s proposed in April, and what ends up getting published as final usually during July.”
Forster did note that last year hospice providers saw a jump of roughly a percentage point between what was in the proposed rule and what came out in the final rule. That was primarily due to higher inflation.
“From what we’ve seen so far this year, the inflation rates have not been as aggressive as they were last year at this time,” Forster said. “Although, I will say that hospices are still experiencing a lot of financial strains around workforce issues, staffing, all of those types of things.”
Similar to their hospice counterparts, home health providers are still struggling with staffing constraints.
Since the home health rule is proposed later than hospice, the former may see a slightly higher or lower payment update than the latter, depending on how inflation trends shake out. But that will depend on the data that ends up being used as the basis for the proposed payment update.
Hospice also saw no major changes relative to the wage index, and Forster anticipates that this will be the case for home health as well.
One major element of the proposed rule for hospice is an increased focus on integrity in the hospice program.
The U.S. Centers for Medicare & Medicaid Services (CMS) has included what was referred to as “deep dive” into hospice utilization trends, as well as related data, that are cause for concern.
Will this be the same for home health providers? Yes and no, according to Forster.
“We do know that there are some activities around the proliferation of hospice agencies, which is something that we’ve seen a lot of in some of the western states,” she said. “While this has been a heavy focus in hospice, we’re hearing that there may be some similar activities going on relative to home health agencies.”
Still, Forster casts doubts on whether the degree of oversight will be the same.
“We could see CMS taking a look at some of these new players that are coming in to be certified under Medicare, and doing some of the same oversight that they’re initiating relative to these new players in hospice, but I don’t think it will be as aggressive as the the work that’s being done in the in the hospice area,” she said.
Aside from the payment update and an increased focus on integrity within the program, the proposed rule for hospice includes a request for information (RFI) on health equity.
“We expect to see similar, if not the same questions, put forward in the home health rule,” Forster said. “Home health and hospice are in very similar places relative to the development of measures that are indicators of health equity.”
Ultimately, while home health providers have seen some improvements to their operating environment, they are still up against a handful of headwinds. These factors may play a role in what the proposed payment rule will look like.
“Staffing has always been a significant area of concern, and it’s something that got worse during the pandemic, and just really has not abated,” Forster said. “But some of the other factors, such as cost of gasoline, some of the costs of goods and services — some of those things are not as problematic as they were last year at this time.”
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