Hospice

~~~~~Hospice updates for 1135 waiver~~~~~

For both hospice and home health, CMS will continue to pay for the administering of COVID-19 vaccines and some antibodies. However, when it comes to telehealth services and the Public Health Emergency (PHE), hospice, and home health differ. Face-to-Face encounters via telehealth will only be permitted for hospices and must be done using a HIPAA-compliant telehealth system. Click here for more information. Effective May 12, 2023, routine home care visits for hospice will no longer be allowed via telehealth. 

Hospice providers must ensure that all Face-to-Face encounters conducted via telehealth are accurately documented in the patient’s medical record. Such encounters must be audio and video-enabled, and documentation must reflect this. The temporary allowance of telehealth for Face-to-Face encounters has been extended through December 31, 2024. Therefore, it is essential for hospice providers to maintain accurate records in compliance with current regulations.  

The end of the PHE will end two 1135 waivers regarding hospice aides. These waivers include the requirement for an annual on-site, in-person visit and the need to provide 12 hours of education for hospice aides annually. Hospice providers will now be obligated to comply with these regulations.  

Another item is the QAPI program returning to the full scope of requirements including the current focus on infection control.  

After the expiration of the 1135 waivers, hospices will need to return to their pre-emergency requirements for volunteer services; specifically, hospices must ensure that at least 5% of patient care hours are made up of volunteer hours.  

A fact sheet for the items ending or adjusted with the end of the PHE is available for ease of reference.  

The National Association for Home Care and Hospice recently hosted a webinar to explain the changes that must be made by May 12, 2023, and it’s important to review this information carefully to ensure compliance with all relevant regulations. To stay informed and up-to-date, individuals should access the webinar for further clarification. 

~~~~~Measure Exclusions for Patients Transferred or Discharged to Hospice (1/1/2023)~~~~~ 

As cited in the Expanded HHVBP Model Frequently Asked Questions (FAQs), Q3020.1, quality episodes for patients discharged (RFA 9) to a non-institutional hospice (M2420 = 3) where M0906 (Discharge/Transfer/Death Date) is 1/1/2023 or later are excluded from all OASIS-based applicable measures:

• Improvement in Dyspnea

• Improvement in Management of Oral Medications

• Total Normalized Composite (TNC) Change in Mobility

• Total Normalized Composite (TNC) Change in Self-Care

• Discharged to Community

  • Note that for the Discharged to Community measure, quality episodes in which patients were transferred to an institutional hospice (M2410 = 4) and with an M0906 Discharge/Transfer/Death Date of 1/1/2023 or later are also excluded from the measure.

The Home Health Quality Reporting Program Measure Calculations and Reporting User’s Manual Version 2.0, available on the Home Health Quality Measures webpage, contains additional information about the Home Health Quality Reporting Program (HH QRP) measure calculations.