CMS Establishing a Hospice Quality Reporting Program

The Centers for Medicare & Medicaid Services (“CMS”) announced in a Federal Register notice that it is creating a new data-collection program for hospice quality reporting called the Hospice Item Set (“HIS”) System.

The HIS System, which is mandated under Section 3004(c) of the Patient Protection and Affordable Care Act of 2010 (“ACA”), establishes a new system of records for patient-level data collection. CMS states that the data will confirm whether the appropriate assessments were made, and whether inquiries and concerns were addressed, for each hospice patient. The data CMS plans to collect for each patient includes:

• Pain,
• Respiratory status,
• Medications,
• Patient preferences, and • Beliefs and values.

Under the program, which hospices must begin using by July 1, 2014, hospices will submit information to the system at the time of admission (and at the time of discharge if a patient does not die).

CMS plans to use strict time limits regarding submission of the information. Hospices must complete admission forms within 14 days of entry, and where applicable, complete discharge forms within 7 days of discharge. The forms must be submitted to the CMS system within 30 days of admission or discharge. Failure to timely report the information could result in cuts to CMS reimbursements.

Notably, under the new information system, information will be collected on all hospice patients, not just patients who are Medicare beneficiaries.

For more information on this topic, you can reach Abby Pendleton, Esq. at apendleton@thehlp.com or Jessica Gustafson, Esq. at jgustafson@thehlp.com.