On December 13, 2019, the National Hospice and Palliative Care Organization and the Medicare Rights Center submitted a letter to the Centers for Medicare & Medicaid Services (CMS) requesting the addition of consumer protections to a CMS proposal to carve in the Medicare hospice benefit in Medicare Advantage, as well as a delay in implementation of at least one year.
As it stands, the CMS Innovation Center is planning to expand the Value-Based Insurance Design (VBID) Model to allow Medicare Advantage plans to include hospice coverage in plan designs for the first time in 2021. Since the inception of Medicare Part C, MA plans have “carved out” hospice care, leaving plan enrollees to receive end-of-life care under traditional Medicare Part A.
The VBID model is designed to reduce Medicare program expenditures, enhance the quality of care for Medicare beneficiaries, and improve the coordination and efficiency of health care service delivery. CMS has not yet shared information necessary for plans to begin to include hospice in their covered benefits, contract with providers, or communicate with consumers. From the limited details currently available, it is impossible to assess whether stakeholder feedback has been incorporated into the design of this new model.
“We are thrilled that CMS and the Innovation Center are making efforts to increase access to care for seriously ill patients and their families,” said NHPCO President and CEO Edo Banach. “However, we are concerned that hospices and plans will not have sufficient time to assure that any model will enhance access to quality hospice care.”
To ensure the model best promotes beneficiary access to high-quality hospice care, NHPCO and the Medicare Rights Center urge CMS to release information about the policy and its operational details without delay.
NHPCO and the Medicare Rights Center are also requesting that an Ombudsman Program be established to support the model and those who will be impacted by its implementation – payers, providers, and most importantly, patients.
Download the PDF of the letter from NHPCO and MRC.