CMS Releases Fiscal Year (FY) 2025 Hospice Wage Index and Payment Rate Update, Quality Reporting Proposed Rule

NHPCO Regulatory Alert

[Last Thursday] at 4:15 p.m. ET, the fiscal year (FY) 2025 Hospice Wage Index and Payment Rate Update, Hospice Conditions of Participation Updates, and Hospice Quality Reporting Program proposed rule was posted for public inspection at the Federal Register. The Centers for Medicare & Medicaid Services (CMS) has released a fact sheet accompanying the proposed rule. Comments on the proposed rule are due by May 28, 2024.

Key provisions include:

  • Proposed Payment Rate Increase. CMS is proposing a 2.6% increase for FY 2025, which reflects a 3.0% market basket percentage increase, decreased by a 0.4 percentage point productivity adjustment.

  • Proposed Hospice Cap Amount. CMS proposes a hospice cap amount for the FY 2025 cap year of $34,364.85, which is equal to the FY 2024 cap amount ($33,494.01) updated by the proposed FY 2025 hospice payment update percentage of 2.6%.

  • Hospice Outcomes and Patient Evaluation (HOPE) Data Collection Tool. CMS proposes to begin collecting HOPE patient-level data collection data on or after October 1, 2025, which would replace the existing Hospice Item Set (HIS).

  • Quality Measures. CMS proposes two new quality process measures based on HOPE data, including ‘Timely Reassessment of Pain Impact’ and ‘Timely Reassessment of Non-Pain Symptom Impact.’ Implementation of these measures would begin in FY 2028.

  • CAHPS® Hospice Survey. CMS is making several changes to the CAHPS® Hospice Survey, including the addition of a web-mail mode survey option.

  • Hospice Conditions of Participation (CoPs). CMS proposes to align Medicare hospice payment and CoP requirements by clarifying that the medical director, physician designee if the medical director is unavailable, or a physician member of the hospice interdisciplinary group may review patient clinical information and certify a patient’s terminal illness.

  • Change to Statistical Areas. CMS proposes to update the labor market delineations based on the 2020 Decennial Census. This may result in changes to the wage index rate for some hospices. The 5% cap on wage index decreases year over year will be applied to these changes.

  • Request for Information. The proposed rule includes a request for information regarding the potential implementation of a separate payment mechanism to account for high-intensity palliative care services under the hospice benefit, including chemotherapy, radiation, and transfusions.

NHPCO has begun a review of the proposed rule and will release a detailed analysis in the coming days. NHPCO will also be hosting a webinar on rule provisions on April 25, 2-3 p.m. ET. Any questions can be directed to [email protected] with ‘FY 2025 Hospice Wage Index’ in the subject line.