Hospice Utilization Trends and Changes to the "Labor Shares" of the Payment Rates

Hospice Utilization and Spending Patterns
As is usually the case, as part of the proposed rule, CMS provides analysis of hospice spending and utilization patterns. Numerous items were covered as part of this section including hospice average length of election, median lifetime length of stay, average lifetime length of stay, average live discharge rates, the change in service intensity add-on (SIA) payments, and non-hospice spending under Parts A, B and D. For additional information on hospice utilization and spending patterns, please consult the proposed rule

Rebasing and Revision of the "Labor Shares" of the Hospice Payment Rates
In recent years CMS has indicated an interest in potential changes to the labor/non-labor shares of the hospice payment rates, particularly given the collection of expanded data as part of the revised  hospice cost report. As part of the FY2022 rule, CMS is proposing to rebase and revise the labor shares for Continuous Home Care (CHC), Routine Home Care (RHC), Inpatient Respite Care (IRC), and  General Inpatient Care (GIP) using 2018 cost report data for freestanding hospices.

Following is a table containing the current labor share values as compared with what CMS is proposing:
  Proposed Labor Shares Current Labor Shares
CHC 74.6% 68.71%
RHC 64.7% 68.71%
IRC 60.1% 54.13%
GIP 62.8% 64.01%
Additional information regarding CMS' calculations of the proposed labor shares is included in the proposed rule

Question Title

* 1. CMS is seeking comments on all aspects of the data analysis, and particularly the following:

a. How has the change in patient characteristics (previously hospice was provided primarily to cancer patients but now hospice is serving primarily patients with neurological conditions and organ-based failure ) influenced any changes in the provision of hospice services?

b.  What factors determine how and when visits are made as an individual approaches the end of life?

c.  How do hospices make determinations as to what items, services and drugs are related versus unrelated to the terminal illness and related conditions?

d.  What other factors influence whether or how certain services are furnished to hospice beneficiaries?

Question Title

* 2. Please address the following questions:

a. Do you support CMS' proposed changes to the labor shares of the payment rates?

b. Do you have any specific comments about the proposed labor shares values and/or the method used to arrive at the new values?