NHPCO NewsLine Fall 2019 - 9

Hospital Wage Index Year
CMS finalized the proposal to use
the current fiscal year prereclassified hospital wage index as
the basis for the hospice wage
index. The use of the current year
IPPS hospital wage index is in
place as a wage index
methodology for Medicare's skilled
nursing facility (SNF), home
health and inpatient hospital
prospective payment system. The
wage index values published by
CMS reflect the elimination of the
1-year lag in wage index data.

Changes to the Hospice
Election Statement
CMS finalized the proposal to
amend the hospice election
statement. NHPCO is pleased
that CMS, in the final rule,
allowed a one-year delay in the
effective date - now effective
October 1, 2020 (FY 2021).
NHPCO advocated for the delay,
citing both hospice preparation
and necessary EMR software
vendor adjustments. In addition
to the current requirements for
the hospice election statement,
hospices will be required to
include the following on the
hospice election statement:
■ Information about the holistic,
comprehensive nature of the
Medicare hospice benefit.
■ A statement that, although it
would be rare, there could be
some necessary items, drugs, or
services that will not be covered
by the hospice because the

hospice has determined that
these items, drugs, or services
are to treat a condition that is
unrelated to the terminal illness
and related conditions.
■ Information about beneficiary
cost-sharing for hospice services.
■ Notification of the beneficiary's
(or representative's) right to
request an election statement
addendum (see companion
article, page 13).

Services Unrelated to the
Terminal Illness and Related
Conditions
CMS reiterated their "longstanding position that services
unrelated to the terminal illness
and related conditions should be
exceptional, unusual and rare given
the comprehensive nature of the
services covered under the
Medicare hospice benefit as
articulated upon the
implementation of the benefit (48
FR 56008, 56010, December 16,
1983). To the extent that
individuals receive services outside
of the Medicare hospice benefit
during a hospice election, Medicare
coverage is determined by whether
or not the services are for the
treatment of a condition
completely unrelated to the
individual's terminal illness and
related conditions (48 FR38146,
38148, August 22, 1983)."
CMS cited NHPCO's
"Determining Relatedness to the
Terminal Prognosis Process Flow"
in the final rule as an example of

NHPCO advocated
for the delay, citing
both hospice
preparation and
necessary EMR
software vendor
adjustments.
a "national industry association
engaged in activities with
hospices to communicate a
process for helping hospices make
these relatedness determinations
in the form of clinical decisionmaking process workflows." The
latest version of this document
can be found here (PDF).
While not mentioned in the final
rule, a companion process flow on
"Determination of Hospice
Medication Coverage," (PDF)
developed by the NHPCO
Pharmacist Community in
collaboration with the NHPCO
Regulatory Committee may also
be helpful.

Request for Information
Regarding the Role of Hospice
and Coordination of Care
CMS requested information on
hospice and the relationships

Newsline / Fall 2019

9

https://39k5cm1a9u1968hg74aj3x51-wpengine.netdna-ssl.com/wp-content/uploads/2019/04/NHPCO_Relatedness_Process_Flow_Revised_Version_2.0.pdf https://39k5cm1a9u1968hg74aj3x51-wpengine.netdna-ssl.com/wp-content/uploads/2019/04/NHPCO-Medication-Flow-Chart-Version-1.0.pdf https://39k5cm1a9u1968hg74aj3x51-wpengine.netdna-ssl.com/wp-content/uploads/2019/04/NHPCO-Medication-Flow-Chart-Version-1.0.pdf

NHPCO NewsLine Fall 2019

Table of Contents for the Digital Edition of NHPCO NewsLine Fall 2019