To:  NHPCO Provider Members
From:  Health Policy Team
Date:  
October 10, 2018

Provider Engagement Opportunities

CMS added future quality measure development to their Provider Engagement Opportunities webpage. CMS will keep stakeholders informed of hospice measures that they submit to the National Quality Forum (NQF) Measure Application Process (MAP). The Provider Engagement Opportunities webpage is also where CMS posts opportunities for hospices to be involved in Hospice Quality Reporting Program (HQRP) measure and item development activities such as calls for Technical Expert Panel (TEP) participation and calls for applications for pilot tests. This page also includes in the downloads section, documents related to these provider engagement activities such as the TEP Reports and Measures Under Consideration (MUC).

Current Measure Under Consideration

At this time, CMS is developing a claims-based Transitions from Hospice Care, Followed by Death or Acute Care, Measure, which is posted on the Measures Under Consideration (MUC) list). Hospice providers and the public may provide comments on this proposed measure, prior to the NQF Post-Acute Care/Long-Term Care Workgroup (December 2018) and the NQF Coordinating Committee Workgroup (January 2019). As with any new quality measure, the Transitions from Hospice Measure will be formally proposed through CMS fiscal year hospice rulemaking prior to its implementation.

The Call for Public Comment for this proposed measure ran from March 27, 2018 to April 25, 2018 and received 30 comment letters from individual hospice providers, hospice associations, and other stakeholders, including members of the public.

Preliminary Recommendations for the proposed measure:

CMS stated in a Public Comment Summary Report that comments about the intent of the measure, the eventual implementation of the measure, and the measure specification elements such as the outcome definition, risk adjustment, and exclusions were enlightening and will continue to be considered in the measure development process.

Updates to the measure specifications:

  • CMS and the measure developer contractor will take the suggested modifications into consideration, continue to conduct data analysis, and discuss with national experts and stakeholders to determine potential measure modifications.
  • CMS will list potential changes to the measure specs based on public comment feedback.
  • CMS and the measure developer contractor will perform further analysis to test the effects of several recommendations, such as excluding hospice patients who were discharged for reasons other than being no longer terminally ill and exploring potential methods for including Medicare Advantage patients.
  • CMS and the measure developer will also consider feedback requesting further training and explanation about how the measure will eventually be implemented.

Read the CMS Public Comment Summary Report

Please email questions about this alert to NHPCO at quality@nhpco.org.