CMS Final Rule for FY 2020: Postponing the Addendum Doesn’t Mean You Should Ignore It
As CMS’s final rule for FY 2020 was heading toward the finish line, it had many hospice providers frustrated and concerned. In addition to reducing reimbursement 2.6% for routine home care – the level that represents 97.6% of all hospice care – the final rule originally included a provision requiring hospices to provide an addendum explaining the rationales for services, drugs and items the hospice has determined to be unrelated to the terminal illness.
Providers are apprehensive about the extra work required to complete the addendum at the level of detail CMS is mandating. The addendum is layered on top of the existing requirement to tell patients which services won’t be covered by the hospice benefit. Explaining the details of what will be covered – and what won’t be – in language the patient and family can understand may be labor intensive. CMS has no plans to supply a form for the addendum, so each provider will have to create their own format that can be tailored to individual patients and include all the information CMS requires under the rule.
While this provision was deferred to FY 2021, much to the relief of providers, the decision means you have extra time to plan for how to handle the addendum. And there’s no time like the present to begin.
Here’s another thought: not only will the new provision be labor intensive, it also is the opposite of what patients and families need to hear when trying to understand and embrace hospice care. Let’s focus on what hospice doesn’t do before they truly comprehend all the great things hospice does!
Don’t get me wrong. It’s important that patients and families learn what their hospice benefit covers and what it doesn’t, explained in language they can understand. And that approach should be in effect from the very first encounter with the patient and family.
Speaking the patient and family’s language begins by asking them questions and listening – really listening – to their answers. What is their understanding of the patient’s condition? Do they know which diagnosis the patient’s doctor identified as the terminal one? (With comorbidities often present, it may be confusing.) What are the patient’s goals and wishes for living their final months with their progressing terminal illness? What are their greatest fears and concerns?
By starting with what the patient understands and wants, a hospice provider can frame the message of all the support the hospice benefit will cover to meet their needs as they’ve expressed them. The provider also can explain if certain things won’t be covered when they’re not related to the terminal diagnosis … but that comes after already having the discussion of which diagnosis their doctor deemed terminal.
As noted above, CMS is not providing a form for the required addendum. Maybe there shouldn’t be a form anyway. Because the explanation needs to be personalized to the patient’s exact situation – not filled out in a rote template.
Instead, perhaps your agency can create a solid outline of topics to cover and begin discussing at the initial meeting with the patient and family. Then continue to use the notes you fill in on the outline for ongoing conversations using language that relates back to how the family described their understanding of the situation. Because the “what hospice covers” and “what hospice doesn’t cover” isn’t a one-and-done conversation. Most consumers don’t really understand hospice well at all until they experience it. Start preparing now for this pending requirement from CMS as a springboard to help patients and families comprehend all the benefits hospice DOES provide, defined by their own terms of what’s important to them. Discussions like these will only enhance the overall patient experience.