C-TAC recently submitted comments regarding the proposed 2025 Hospice and Skilled Nursing Facility (SNF) rules. Here are our key points:
Request for Information (RFI) on Payment Mechanism for High Intensity Palliative Care Services
- We pointed out the misleading alignment of the terms “comfort care” and “palliative care” on page 48: Hospice care changes the focus of a patient’s illness to comfort care (palliative care) for pain relief and symptom management from a curative type of care. We went on to note that palliative care encompasses care well before that end-of-life period and using the umbrella term “palliative care” in this context is inaccurate as not all palliative care is hospice or comfort care.
- Continuing this discussion, we said that the use of the term “palliative“ for treatments in this RFI was also problematic. The historic language about curative vs palliative has always been erroneous as chronic conditions, such as heart failure or diabetes, were never curable. And so, any treatment for them is technically palliative in that it helps optimize function and quality of life but doesn’t cure the underlying illness.
- Our suggestions about such treatments were:
- Clarifying with new hospice enrollees upfront what such treatments will be covered and included in the hospice plan of care and expanding those options.
- Having the hospice medical director or nurse case manager coordinate any such additional disease-modifying treatment with the outside specialist(s) involved.
- Providing payments to the clinician or entity delivering these disease-modifying treatments in collaboration with the hospice.
- Recognizing that additional payment for high-cost disease-modifying treatments could allow bad actors to take advantage of them. This would require tight monitoring to flag and reduce that.
Proposals to the Hospice Quality Reporting Program (HQRP)
We supported the addition of the two process measures to the HQRP calculated from data collected from HOPE: Timely Reassessment of Pain Impact and Timely Reassessment of Non-Pain Symptom Impact.
Skilled Nursing Facility (SNF) Quality Measure Concepts Under Consideration for Future Years— Request for Information (RFI)
We provided the following responses:
- Pain Management – We supported this measure concept. We also suggested considering the new Ambulatory Palliative Care Patients’ Experience of Receiving Desired Help for Pain to the SNF QRP as a way to include the patient’s voice on this important area.
- Depression – We supported this measure concept as depression can strongly affect health and quality of life and is often a factor for those living with serious illness.
- Patient Experience of Care/Patient Satisfaction – We also supported measure development in this area as patient self-report is the gold standard to assess care quality. We recommended consideration of the Ambulatory Palliative Care Patients’ Experience of Receiving Desired Help for Pain again and also the 2024 MIPS Measure #495: Ambulatory Palliative Care Patients’ Experience of Feeling Heard and Understood. Both are appropriate for the SNF program to get direct patient self-report on these important aspects of care.
Beyond these areas we also recommended the following measure concepts for future consideration for the SNF quality program:
- Advance care planning (ACP) – This should be required in the SNF QRP, and all Medicare programs, as a way to ensure that the care being delivered is the care that the person wants.
- Palliative care access and utilization – People with serious illness benefit from the inclusion of palliative care services in their care. Therefore, we suggested consideration of a measure in the SNF QRP on referral or access to palliative care to measure how many of those with serious illness getting SNF care are also utilizing these important services.
- Timely and appropriate referral to hospice – We suggested a measure to ensure that a hospice referral is considered when appropriate and that the patient’s eligibility for hospice is assessed and hospice offered.
