Hospices Speak Up on Home Health Proposed Rule

Categories: Leadership and Policy.

NHPCO Comments to CMS Incorporate Concerns of the National Hospice Community

On behalf of the national hospice provider community, the National Hospice and Palliative Care Organization (NHPCO) has submitted detailed comments (PDF) to Centers for Medicare and Medicaid Services (CMS) on the hospice survey reform and enforcement remedies provisions contained in the Calendar Year 2022 Home Health PPS Proposed Rule, also known CMS-1747-P or the Home Health proposed rule. NHPCO’s comments incorporate extensive feedback from NHPCO members and state organizations, gathered through discussions by three NHPCO committees, member surveys and consultations, and workgroups convened to develop specific recommendations regarding key hospice provisions in the rule: accrediting organizations, survey processes, the special focus program, and enforcement remedies.

“NHPCO is pleased to represent the interests of the hospice community in the rulemaking process,” said NHPCO President and CEO, Edo Banach. “The hospice components of the Home Health proposed rule have significant implications for hospices and hospice patients across the country. Before and since the introduction of the Hospice Act in 2020, we have been actively engaged in both the legislative and regulatory processes, informing NHPCO members at each step, and making sure lawmakers and regulators hear their concerns.”

Banach continued, “While the intent of the proposed rule is sound, many of the specifics raise concerns. NHPCO’s recommended revisions to the proposed rule would protect patient interests, bring hospice regulations in line with regulations governing other post-acute care providers, and improve standardization and consistency in hospice accreditation and surveying systems—goals that align with the interests of Congress, CMS, hospices, patients, and the American people.”

NHPCO filed its comments Friday, August 27, 2021, and provided an immediate update through a Regulatory Alert emailed to members. Both the Regulatory Alert and the full comments are available to members on the NHPCO website. For more information, please contact the NHPCO communications team at communications@nhpco.org.

Banach added, “Thank you to the many NHPCO members who took part in the deliberations that shaped these comments—through our committees, surveys, and consultation calls. NHPCO is proud to be your voice in Washington.”


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