NHPCO Responds to Year Two Announcement of Medicare Advantage Hospice Carve In Demonstration

Categories: Leadership and Opinion.

Medicare Advantage VBID Model Fails to Support Beneficiary Needs

The National Hospice and Palliative Care Organization (NHPCO), responded to this week’s announcement from the Centers for Medicare & Medicaid Services (CMS) outlining 2022 participants in the Medicare Advantage (MA) Value-Based Insurance Design (VBID) Model, including MA organizations participating in the Hospice Benefit Component. In January of this year, CMS started offering hospice services through Medicare Advantage plans through VBID.

CMS first announced in January 2019 that Medicare Advantage plans would be able to offer hospice care services starting in 2021 under a demonstration project. NHPCO was initially receptive to a demonstration and offered recommendations on how it could enhance access to community-based, person-centered interdisciplinary care offered by hospice providers. At the end of 2019, we called for a delay in implementation when we learned that the model as designed lacked sufficient beneficiary protections. When COVID-19 cases started to rise rapidly in the spring of 2020, together with Families USA and the Medicare Rights Center, NHPCO implored CMS to move the launch date while hospices directed their energy and resources toward ensuring uninterrupted care in the face of an emerging global pandemic. Nonetheless, CMS hastily proceeded to launch the hospice component of VBID.

One component of the VBID hospice benefit that differs from traditional Medicare hospice care is called “transitional concurrent care,” which allows a patient to receive palliative care for serious illness concurrent with a transition to hospice care for those nearing the end of life. However, VIBD has not defined a required set of core services for “comprehensive palliative care” that a Medicare Advantage plan can offer to effectively implement concurrent care. We believe that all beneficiaries facing serious and life-limiting illness deserve well-defined services. Without that, they can be denied access to the care they deserve.

NHPCO President and CEO, Edo Banach, said, “Nearly a year into the demonstration, CMS has not shared data or explained how this demonstration improves access to hospice care. We see no evidence to support a second implementation year. Furthermore, providers and consumer advocates are disheartened by CMS’s decision to continue with this experiment while many states are experiencing their highest COVID-19 positivity rates, hospitalizations, and worst workforce shortages since the beginning of the pandemic. Especially in the face of a public health emergency, we ask CMS to honor its commitment to partner closely with the hospice provider community and consumer groups in their mission to advance health equity, expand coverage, and improve outcomes.”


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