Navigating New Requirements in the 2025 Proposed Hospice Rule

Navigating New Requirements in the 2025 Proposed Hospice Rule

If the U.S. Centers for Medicare and Medicaid Services (CMS) proposed 2025 hospice rule is finalized as written, hospices may encounter some hurdles in implementing some of the new requirements. 

CMS late last month issued its proposed hospice rule for 2025. The proposal called for a 2.6% increase in hospice per diem base rates, a number that many stakeholders say is insufficient in today’s economic climate. 

But the rule contains more than payment rates. One key element is the planned 2025 implementation of the Hospice Outcomes & Patient Evaluation (HOPE) tool, which will replace the Hospice Item Set.

New Ways to Measure Quality

While hospice organizations have expressed support for the new tool, contingent upon effective implementation, it could also bring some challenges as providers adapt to a new quality reporting system, according to Katy Barnett, director of home care and hospice operations for LeadingAge. 

“With any new tool implementation, there are challenges. [In the HOPE tool] the majority of the questions are nurse-focused, so they’ll have to look at how they’re staffing their nurses in terms of the initial visits and doing the hospice update visits and making sure that their nurses can complete everything in a timely manner,” Barnett told Hospice News. “It’s a new way of thinking about collecting data on patients, and they are going to have to do in-services and training of their entire staff for what this means to the flow of everyday business at the hospice.”

This could mirror to some extent the experience of home health providers, who encountered some technical issues with changes to their OASIS quality reporting system in recent years, she indicated. 

Also, CMS is doing away with the free software that many hospices use to report data for the Hospice Item Set. This will require some new investments in technology and working with vendors to get those systems up and running, Barnett said. 

“Providers need to review the HOPE tool as there are new items and revised items,” Katie Wehri, director of home care and hospice regulatory affairs for the National Association of Home Care & Hospice (NAHC), told Hospice News in an email. “There is also a new timepoint and not all HOPE items are completed at each timepoint. As with any standardized tool it is essential that they review the HOPE manual to ensure they understand how to correctly complete the items.” 

Some elements of the HOPE tool will require some logistical legwork, Patrick Harrison, senior director of regulatory and compliance at the National Hospice and Palliative Care Organization (NHPCO), and Sarah Simmons, director of quality for NHPCO, told Hospice News in a joint email. 

“Overall, hospice providers seem pleased that HOPE will provide a new avenue of capturing assessment data related to the quality of care that hospices provide to their patients, specifically regarding pain and non-pain symptoms,” they said in the email. “One challenge will be the operationalization of Hospice Update Visits, particularly since providers are still looking for clarity on which disciplines can complete those visits. Another challenge is that, as proposed, telehealth reassessments are not permitted for the HOPE-based process measures.”