Comments on December 2020 MedPAC Meeting

NHPCO Concerned about Unintended Consequences on Access and Quality 

At this week’s public meeting, the Medicare Payment Advisory Commission (MedPAC) revisited previously presented policy options to modify the hospice aggregate cap. The presentation consisted of the following draft recommendations for Congress: 

• For fiscal year 2022, eliminate the update to the fiscal year 2021 Medicare base payment rates for hospice, and 
• Wage adjust and reduce the hospice aggregate cap by 20 percent.
  

The National Hospice and Palliative Care Organization continues to be concerned about the unintended consequences of the recommendation to reduce the aggregate cap on beneficiary access and quality of hospice care. NHPCO staff was in attendance at the virtual meeting and although there were no opportunities for public statements during the call, NHPCO will be submitting an official comment letter to MedPAC in response to this recommendation. 

“NHPCO does not support MedPAC’s recommendation to modify the hospice aggregate cap. As we have stressed, without reliable data, it is unclear how such reductions would lead to Medicare savings, increase access to care, or lead to higher quality of care,” said NHPCO President and CEO Edo Banach.  

“NHPCO shares MedPAC’s goals, but this approach appears overly broad, especially in light of the strain put on providers by the COVID-19 pandemic. If the recommendation is adopted by Congress, it could lead to a decrease in hospice access for patients and families, especially in rural and underserved areas. In the short term, we urge MedPAC to use a targeted approach that will have a higher likelihood of rewarding high quality, punishing low quality, and increasing access,” Banach added. 

In addition to hospice payment policy, MedPAC staff discussed the completion of a Congressionally mandated report, requested by Congress after hospice was added to the post-acute care (PAC) transfer policy. The policy reduces IPPS payments for short stays followed by transfer to PAC.  The final results showed “savings to the Medicare program of about $300M in FY2019 with no evidence of discernable changes in timely access to hospice care.”    

MedPAC will have their regularly scheduled meeting on January 14 and 15, 2021 to have a final vote on these recommendations for the publication of the March 2021 Report to Congress. NHPCO reminds hospice providers that MedPAC is an advisory body that makes recommendations to Congress.   

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