National End-of-Life Organizations Release Consensus Statement on Hospice, the Medicare Hospice Benefit, and Key Issues for ...(nsparency and fair regulatory scrutiny. ...),Health

Responses to draft MedPAC Recommendations, dated 11/6/08:

Recommendation #1: The Congress should change the current Medicare payment system for hospice to reduce payments per day as the length of the episode increases. The revised payment system should include a payment adjustment to reflect hospices' higher costs associated with patient death at the end of the episode.

A payment system that more closely matches or "tracks" actual cost curves of patient care, such as a "first and last periods of care" system, done on a budget neutral basis, has merit. There are key issues in developing such a design that need to be substantiated and tested against comprehensive and broad-based data. Only after such data is collected, analyzed, and understood, can it serve as the basis for rational and appropriate payment reform.

Recommendation #2a: The Congress should direct the Secretary to:

• Require that a hospice physician or advanced practice nurse personally visit the patient to determine continued eligibility at 180 days and at each subsequent recertification and attest that such visits took place;
• Require that certifications and re-certifications include a brief narrative describing the clinical basis for the patient's prognosis; and
• Require that all stays in excess of 180 days be reviewed by the applicable medical director of the Medicare claims processing contractor for hospices with an average length of stay greater than 120 days.

Certain additional safeguards might be put into place given changing patient demographics and, in some isolated instances, very long lengths of stay for patient. Included in this area is the need for
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