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Comments on the FY 2018 Proposed Hospice Rule

LeadingAge NY, along with the Hospice and Palliative Care Association of NYS (HPCANYS), collaborated with LeadingAge National to provide comments on the Centers for Medicare & Medicaid Services (CMS) [CMS-1675-P] Medicare Program; FY 2018 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements proposed rule that was posted in the May 3rd Federal Register. Our comments were submitted on June 16th.

Our comments on several sections of the proposed rule included:

  • Section III.C Discussion and Solicitation of Comments Regarding Sources of Clinical Information for Certifying Terminal Illness;
  • Section III. D2 General Considerations Used For Selection of Quality Measures for the HQRP;
  • Section III. D7 Measure Concepts Under Consideration for Future Years; and
  • Section VI. Request for Information on CMS Flexibilities and Efficiencies.

HPCANYS also submitted comments reflecting more from the state’s perspective. Their letter to CMS incorporated comments and recommendations on:

  • Trends in hospice utilization;
  • Live discharge rates;
  • Skilled visits in the last days of life;
  • Non-hospice spending;
  • Hospice caps;
  • Sources of Clinical Information for Certifying Terminal Illness;
  • Updates to Hospice Quality Reporting Program (HQRP);
  • Public Display of Hospice Data; and
  • Request for Information on CMS Flexibilities and Efficiencies.

Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871