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Expert Breakdown: Hospice Proposed Final Rule

Headlines would have you think that the recently released FY 2025 Hospice Proposed Final Rule from the Centers for Medicare and Medicaid Services (CMS) is good news. And for the most part, it is, says ̲app Vice President of Hospice Professional Services Zaundra Ellis. The story that the headlines don’t tell is that there is more nuance to what CMS is proposing than just a payment rate increase or typical regulatory moves. Ellis combed through the entire rule to dig out the most important components that will help hospice providers adapt to everything coming their way.

Proposed Payment Increase

The banner headline seen everywhere is the proposed 2.6% payment increase for providers along with an aligned increase of the hospice capitation rate. Rising payment rates are sure to be welcome news for providers, especially given that CMS has proposed cutting payment rates in home health multiple times over the past five years. But Ellis notes that even with this increase, CMS could, and should, do more.

“It’s not enough,” said Ellis. “The increase doesn’t even scratch the surface when you factor in inflation on top of the cost to care for patients. I will be working with [the National Hospice and Palliative Care Organization] and ̲app’ public policy team to draft public comment letters to CMS letting them know why more is needed.”

HOPE is on the Horizon

A new assessment that has been years in the making finally has a proposed launch date. The Hospice Outcomes and Patient Evaluation (HOPE) would replace the Hospice Item Set (HIS) starting October 1, 2025. That might seem like a long lead time before implementation but Ellis urges providers to start thinking about HOPE now.

“We need to start acting like [HOPE] is happening this year because it’s going to take some adjustment,” said Ellis. “Hospices need to figure out what they’re being asked to do with the changeover from HIS data collection to the new HOPE tool.”

“Hospices need to start educating their IDG about the HOPE tool and how the information [from the HIS that is] being presented in meetings now will be different than data gathered with the HOPE assessment.”

HOPE data would also be required to be submitted to CMS through an electronic medical record (EMR) such as ̲app Hospice. The assessment would also have to be completed at admission, discharge and at two Hospice Update Visit (HUV) time points within the first 30 days after hospice election for applicable patient stays. The breakdown of the schedule is below:

  • Admission assessment: Days 1-5
  • HUV: Days 6-15
  • HUV: Days 15-30

The full draft of HOPE and the technical manual is available to review on the .

Hospice CAHPS Updates

CMS is proposing changes to the CAHPS that would be effective for decedents after January 1, 2025. Ellis says that the overall move CMS is making is to slim down the survey and make it more approachable with simplified wording of questions.

“CMS is finally moving the CAHPS survey forward and really thinking about the customer experience and what happens when they get the survey,” said Ellis. “Their proposed changes reflect the idea of ‘what can we do to help get people to respond in a timely manner?’.”

The proposed changes include removing three questions related to care received in a nursing home, which Ellis says is a good move since the questions weren’t specific to the hospice staff care but rather care from facility staff.

Two new CAHPS questions would be added as part of a new “Care Preference” measure. The questions include:

  • Did the hospice team make an effort to listen to the things that mattered most to you or your family member?
  • Did the hospice team provide care that respected your family member’s wishes?

Ellis applauded the move. “People have different needs and desires at the end of life and it’s very personal. So, we need to make that connection with them and really understand that.”

And CMS is also proposing adding a new way to conduct the survey over the internet. Currently the only approved survey modes are through letters mailed directly to an address or over the telephone. The change would involve sending an email to recipients who could take the CAHPS survey online. Letters would be mailed to recipients ahead of time to alert them to look for the email and the importance of a response.

When looking at the totality of what CMS is proposing in the FY Hospice Proposed Final Rule, Ellis is optimistic.

“I think that that’s very hopeful and it really shows that CMS is going to be focusing on the patient experience and that’s really what it’s about.”

Public comment letters on the FY 2025 Hospice Proposed Final Rule are due by May 28. Click to add your comments.

̲app Hospice, a cloud-based hospice software, includes simple tools such as intuitive medication management and real-time plan of care updates to help keep organizations compliant.


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