Hospice Community Sees CMS VBID Model as a Missed Opportunity

Categories: Policy.

NHPCO shares concerns over newly announced CMMI demonstration that will allow Medicare Advantage plans to include hospice care in 2021.

On December 19, 2019, the Centers for Medicare & Medicaid Services Innovation Center (CMMI) released the Request for Applications for the Value-Based Insurance Design (VBID) Model that will allow Medicare Advantage (MA) plans to include hospice coverage in plan designs for the first time in 2021. While the National Hospice and Palliative Care Organization supports innovation that enhances opportunity for access to high-quality, interdisciplinary care, NHPCO continues to have serious concerns about timing for implementation, the impact on beneficiary access to high-quality care, and lack of beneficiary protections.

“The 2021 VBID Model represents a missed opportunity for CMMI to innovate the way hospice care is delivered.  While the application mentions ‘palliative care’ and ‘transitional concurrent care,’ and encourages plans to innovate, it does not mandate particular coverage for that care. We have seen that innovation without baseline requirements can sometimes lead to barriers to care.  Additionally, the model does not waive the six-month prognosis requirement for hospice eligibility.  This is a missed opportunity to expand access to hospice.  We are also disappointed in the dearth of necessary consumer protections,” said NHPCO President and CEO Edo Banach.

Enhancing access to person- and family-centered care for the seriously ill and their families is something NHPCO strongly supports. However, NHPCO is concerned that given the lack of sufficient details offered prior to the VBID Request for Applications (RFA) released on December 19, plans do not have sufficient time to establish provider networks, and providers do not have time negotiate contracts with MA plans, especially the many smaller programs that provide high-quality care to underserved and rural areas.

As stated in the RFA, “CMS may change the terms of the Model or cancel it entirely in response to stakeholder comments or other factors.”  We urge CMS to consider stakeholder feedback concerning five specific areas related to the VBID model framework:

Beneficiary Access:
The model does not waive the arbitrary six-month prognosis requirement for being hospice eligible, nor does it allow individuals who become eligible for hospice after they enroll in MA to change plans or choose their preferred hospice provider.  A special enrollment period is essential in addressing this concern and protecting consumers.

Quality/Evaluation:
The RFA lacks details about the quality measures for the model which must be focused on outcomes or based on existing measures so that they are reflective of the actual quality of care provided.  Without sufficient quality measures, it is impossible to determine whether consumers are helped and not harmed by this demonstration.  This puts patients and families at risk.

Payment:
The payment amount for this model may not be adequate for hospices to provide high-quality interdisciplinary care. Unknown details of the payment structure does not incentivize MA plans to educate and enroll patients in hospice.

Delay:
Due to the delay in releasing the RFA, hospices do not have sufficient time to negotiate contracts, and establish appropriate practices. This takes significant time, especially for smaller providers that provide high quality care to underserved and rural areas.

Consumer Protection:
Constructing an Ombudsman Program for beneficiaries served under this model is imperative to ensuring beneficiary rights and protections.

In a letter that NHPCO and the Medicare Rights Center submitted to CMS on December 13, 2019, the two organizations requested a delay in implementation of the 2021 VBID model by at least one year as well as the addition of consumer protections.

NHPCO appreciates the ongoing engagement CMMI has had with the hospice community and looks forward to continued integration of stakeholder feedback into the VBID demonstration.

Access the CMS fact sheet available in the newsroom at cms.gov.