Adjusting the Hospice Aggregate Cap Amount: The hospice aggregate cap amount determines the maximum amount a hospice will be reimbursed for services for one year. We recommend reassessing the Medicare hospice cap and utilizing a portion of these savings to support the efforts and sustained effectiveness of community-integrated and rural not-for-profit providers. For instance, there could be an outlier policy that would allow for a 15 percent adjustment to the cap for rural hospices. NPHI recommends a 15% reduction in the annual aggregate hospice cap amount with a safe harbor adjustment for rural hospices.

Diagnosis Versus Prognosis: NPHI recommends that payment for hospice services be based on those issues related to a patient’s terminal diagnosis rather than on all the issues that “influence” a patient’s diagnosis, many of which are outside of the control and expertise of a hospice provider.

Elimination of the Hospice Market Basket Update Caps Set to Begin in 2018: Included in the Medicare Access and CHIP Reauthorization Act (MACRA) was a provision that capped market basket updates for all post - acute care providers, including hospice programs. The provision, which is to start in 2018, limits the annual market basket update for all providers to one percent in any given year. Given the other payment reductions experienced since 2009, NPHI asserts that this cut would disproportionately impact smaller, rural, and not-for-profit hospices whose thin margins can ill-afford another payment reduction. NPHI recommends the elimination of these market basket update caps and safe harbors for not-for-profit providers in future reimbursement decisions.


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