CMS Plan: Home Health & Advance Care—Pay Cuts Loom?

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CMS Proposal Links Reimbursement to End-of-Life Discussions, Raising Concerns for Home Health

The Centers for Medicare & Medicaid Services (CMS) has proposed a new quality measure that could significantly alter how healthcare providers are reimbursed for advance care planning, potentially leaving home health agencies facing financial challenges. The proposed rule, designated MUC202-020, ties payment to documented conversations about end-of-life care preferences, a move lauded for its potential to improve patient-centered care but criticized for its uneven application across healthcare settings.

The implications of this measure are far-reaching, impacting hospitals, skilled nursing facilities, ambulatory surgery centers, and crucially, the home health sector. With a growing emphasis on value-based care, CMS is seeking to incentivize proactive discussions about patient wishes, but the lack of a clear payment pathway for home health agencies raises questions about equitable implementation.

Understanding the Advance Care Planning Quality Measure

The proposed MUC202-020 measure requires healthcare providers to track documentation of advance care planning for all patients aged 18 and older, particularly those with inpatient stays. This documentation must demonstrate that patients have engaged in conversations about their end-of-life preferences, including values, quality of life considerations, and the designation of a surrogate decision-maker. The measure will also be integrated into the Merit-Based Incentive Payment System (MIPS), further incentivizing compliance.

While the National Alliance for Care at Home supports the underlying goal of promoting advance care planning, they’ve expressed concerns about the practicalities of implementation. A key point of contention is the exclusion of the Hospice Quality Reporting Program from the measure, despite advance care planning being a cornerstone of high-quality hospice care. Currently, physicians and qualified healthcare practitioners receive reimbursement for these discussions, but home health agencies do not, creating a disparity in financial support.

Tatiania Fofanova, CEO of Koda Health, a technology company specializing in advance care planning, estimates that the measure could generate substantial savings for the healthcare system. “The cost on the American taxpayer is continuing to rise,” Fofanova explained to Hospice News. “We want to intervene and guide the trajectory of care far earlier on, so that we can make sure that patient preferences and the care they receive are aligned years and years before they get to that end-of-life event.”

The need for proactive advance care planning is underscored by statistics showing that only approximately 36% of U.S. adults have documented their end-of-life wishes. This often results in patients receiving more aggressive, and potentially unwanted, medical interventions. Furthermore, research published in the JCO Oncology Practice journal indicates a strong correlation between advance care planning and increased utilization of hospice services.

Bryan Sivak, founder and managing partner of the venture capital firm Evidenced and a former Chief Technology Officer for CMS, highlights the significant financial burden of unaddressed end-of-life preferences. “Something like $200 billion a year is spent on care that patients say they wouldn’t want,” Sivak stated. “If we’re looking at ways to save money across the board in health care, this is a no-brainer.”

Koda Health, founded in 2020 by Tatiania Fofanova, Dr. Desh Mohan, and Katelin Cherry, emerged from the Texas Medical Center’s Biodesign program, focused on developing innovative healthcare solutions. The company aims to facilitate more meaningful and comprehensive advance care planning conversations.

Dr. Desh Mohan, Koda Health’s Chief Medical Officer, emphasizes the importance of a high-quality advance care planning process. “The requirements would be whether there’s documentation in the electronic health record of advanced care planning taking place,” Mohan explained. “That’s going to be an important consideration going forward to make sure that this is not just a check-box measure.” A robust process, according to Mohan, should encompass a thorough understanding of the patient’s values, quality of life preferences, and a clearly designated surrogate decision-maker.

The National Partnership for Healthcare and Hospice Innovation has publicly endorsed the proposed measure, signaling broad support for its intent.

Pro Tip: Healthcare organizations should proactively assess their current advance care planning processes and identify gaps in documentation and training to prepare for potential implementation of MUC202-020.

What steps can home health agencies take to advocate for equitable reimbursement for advance care planning services? And how can technology, like that offered by Koda Health, help streamline and improve the quality of these crucial conversations?

Frequently Asked Questions About the CMS Advance Care Planning Proposal

  • What is the primary goal of the CMS advance care planning quality measure?

    The main objective is to encourage proactive conversations between patients and healthcare providers regarding end-of-life care preferences, ultimately aligning medical treatment with individual values.

  • How will the MUC202-020 measure impact home health agencies?

    Home health agencies may face challenges due to the lack of a clear payment mechanism for advance care planning conversations, potentially leading to financial losses if the measure is finalized as proposed.

  • What constitutes a “high-quality” advance care planning process, according to Koda Health?

    A high-quality process involves documenting a patient’s values, quality of life preferences, designating a surrogate decision-maker, and ensuring a comprehensive understanding of their goals.

  • What percentage of U.S. adults currently have documented end-of-life wishes?

    Research indicates that only around 36% of U.S. adults have formally documented their end-of-life wishes, highlighting a significant gap in proactive care planning.

  • How much money is estimated to be spent annually on healthcare that patients would not want?

    Experts estimate that approximately $200 billion per year is spent on medical care that patients have indicated they would not desire, emphasizing the potential cost savings of advance care planning.

Share this article with your network to spark a conversation about the future of advance care planning and its impact on healthcare delivery. Join the discussion in the comments below!

Disclaimer: This article provides general information and should not be considered medical or legal advice. Consult with a qualified healthcare professional for personalized guidance.


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