NHPCO Comment Letter
For Immediate Release:
June 10, 2020
NHPCO Comments on FY 2021 Hospice Wage Index and Payment Update Proposed Rule
(Alexandria, Va) – The National Hospice and Palliative Care Organization submitted comments on the FY 2021 Hospice Wage Index and Payment Update Proposed Rule. Highlights from the NHPCO recommendations that were sent to Centers for Medicare and Medicaid Services on June 9, 2020, include:
- Support for the 2.6% market basket increase for FY 2021.
- Support for the 5% limit for a one-year transition when a Core-Based Statistical Area (CBSA) wage index decreases.
- Delay the implementation of the election statement and addendum for at least one full year beyond the end of the COVID-19 public health emergency (PHE).
- Request additional clarification on patient death before the five day time frame to issue the addendum, who can request an addendum, and what steps to take when a patient or representative refuses to sign the addendum.
- Clarify the relationship between the addendum and the Advance Beneficiary Notice (ABN).
- Allow an electronic format for the election statement and addendum and provide guidance on electronic signatures for beneficiaries and representatives.
- Object to the addendum being identified as a condition of payment.
- Detailed recommendations on changes to both the election statement and the proposed addendum examples
NHPCO Members can download a comprehensive Regulatory Alert offering more detailed analysis in the Regulatory Alert and Update page of the NHPCO website.
Vice President, Communications