The Center for Medicare Advocacy Submits Comments on Proposed Rule for Hospice

The Center for Medicare Advocacy submitted comments this week to the Centers for Medicare & Medicaid Services (CMS) concerning its proposed rule titled “Medicare Program; FY 2017 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements” (81 Fed. Reg. 25498), which was published on April 28, 2016.[1]  The Center’s comments focused on proposed quality measures and the forthcoming Hospice Compare website.

The Center expressed support for the composite measure concerning tracking the number of visits by physicians, social workers, clergy, spiritual counselors, licensed practical nurses, or hospice aides in the final days of life.  The Center also supported the second composite measure, an aggregate assessment and scoring of all seven existing Hospice Information Set process measures at admission, as long as such appraisals do not take away from the provision of hospice services to the patient and their loved ones.

In addition, while generally supportive the proposed Hospice Compare website, the Center urged caution regarding the ability of hospice providers to edit self-reported data prior to its submission to Hospice Compare. The Center also suggested that augmenting existing self-reported process measures with objective outcome measures would provide valuable information to providers and prospective patients, and could further enhance the quality of care delivered to beneficiaries.

The Center’s Comments are available at:

June 22, 2016 – M. Hubbard

[1] CMS. “Proposed Hospice Quality Measures and Information Collection Methods.” 28 April 2016.  (site visited June 20, 2016).